For accountants, Tranche 2, 1 July 2026
Tranche 2 compliance
without becoming a compliance officer.
Not every accounting service is a designated service, but enough of them are that public-practice firms get pulled into the AUSTRAC perimeter. Company formations, trust structures, SMSF establishments, and tax-affairs advice on certain transactions all trigger obligations. Caltury runs the workflow alongside your existing engagement process, starting at A$99 a month.
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Accounting Tranche 2 facts
01 Jul 2026
- AU public-practice firms
- ~30,000
- Civil penalty cap
- A$22.2m
- Annual review cadence
- 13 calendar months
- Records retention
- 7 years
- Caltury starting price
- A$99 ex GST/mo
Source: AUSTRAC, AML/CTF Act 2006 (Cth)
Built to
AUSTRAC AML/CTF Act 2006
Identity
Stripe Identity
Sanctions
OpenSanctions
Hosted
Sydney, AU
When the customer is an entity
The buyer is a company. Caltury captures every controller.
Tranche 2 requires you to identify every individual with 25% or more of an entity customer. Caltury auto-detects directors and shareholders from the ABN/ACN, builds the related-party tree, and screens every controller against sanctions and PEP lists in the same step. You see one screen, not five.
- Companies, trusts, partnerships, SMSFs — branched form built in
- AUSTRAC AML/CTF Rules part 8 captured for each controller
- PEP/sanctions screening runs on every party
Entity customer · related parties
4 mappedNorthbridge Holdings Pty Ltd
Corporate trustee
Anika Rao
Director · 40%
Daniel Rao
Director · 35%
Rao Family Trust
Beneficiary class
Sanctions & PEP · OpenSanctions
Why this hits you
The hard part is knowing which engagements are in scope.
Designated-service scoping is non-obvious
A tax return alone isn't a designated service. But forming a company, establishing a trust, setting up an SMSF, or providing advice on the structure of certain transactions can be. Caltury includes a designated-service classifier in the customer flow so you only KYC the engagements that trigger it.
TCSP-flavoured work pulls you into BO capture
When you form a company or trust for a client, you're acting as a Trust and Company Service Provider for that engagement. AUSTRAC expects beneficial-owner identification of every party in the chain. Caltury's customer form branches by entity type so the right parties are captured.
The principal carries the AUSTRAC penalty
Civil penalties under the AML/CTF Act run to A$22.2m per contravention, assessed against the reporting entity. For a partnership firm that's the partners. The Compliance Officer designation has to be a real person who knows their obligations.
The workflow
How a new client engagement flows through Caltury.
Engagement letter signed, customer created
You record the client, pick the designated service from the AUSTRAC catalogue (or 'not a designated service' if it's pure tax compliance). The choice drives whether KYC is required for this engagement.
KYC + beneficial ownership captured if in scope
Individual clients: Stripe Identity verifies via the AU DVS. Company / trust clients: the form branches so 25%+ owners (companies), trustee + settlor + beneficiaries (trusts), and every partner (partnerships) are captured. Sole-trader clients: ABN auto-lookup pre-fills the registered details.
Sanctions and PEP screening
Every party screened against OpenSanctions (DFAT, OFAC, EU, UN, ~150 lists). Risk-rated re-screen cadence: 6 months for high-risk, annual for medium, 3 years for low.
Documented risk assessment per client
Factors weighted by Caltury (jurisdiction, structure complexity, source-of-funds clarity, sector). Drives the customer's risk tier and the depth of ongoing CDD.
Suspicions captured as SMRs
If anything in the engagement raises a suspicion (unusual source of funds, inconsistent answers, refusal to provide ID), Caltury drafts the SMR in AUSTRAC's 5-section narrative format from your facts. You review and lodge via AUSTRAC Online within 3 business days (24 hours for terrorism financing).
Cross-border instructions trigger IFTI
If your engagement involves arranging an international wire on the client's behalf, that's an IFTI. Caltury captures sender / recipient / institution and tracks the 10 business-day lodgement deadline.
Annual independent review, on rails
AML/CTF Rule 8.6 requires an independent review every 13 calendar months. Caltury runs the review wizard, links reviewer findings, and won't sign off without either reviewer findings or a documented skip reason.
Scenarios
What it looks like when something is off.
Not ready to start? Get the free Tranche 2 checklist.
The 40-point checklist covering AUSTRAC enrolment, your AML/CTF Program, KYC, sanctions screening, record-keeping and staff training. We email you the link plus a few short, useful follow-ups on getting ready before 1 July 2026. Unsubscribe in one click.
10 days until 1 July 2026