As Australia prepares for the expansion of its AML/CTF regime to include Tranche 2 entities from 1 July, many businesses are beginning to assess what compliance will mean in practice. While these sectors are not currently captured under the existing framework, the upcoming changes mean organisations will soon need to implement systems and processes to meet their AML/CTF obligations.
With this shift has come an increasing number of providers offering solutions to help organisations prepare. However, not all approaches are the same and it is important for businesses to understand what effective compliance support should look like.
At AMLHUB, our focus has always been simple: provide the technology, operational capability, and education that organisations need to remain confidently compliant.
A key principle of AML legislation is that it is risk-based. This means organisations must understand who their customer is and the nature and purpose of the business relationship and transactions they undertake.
This is why we collect information such as the purpose behind a sale or purchase, as well as the expected transaction value or range. These elements are not arbitrary, they form part of the core information required to assess risk and determine whether a customer's activity aligns with their expected behaviour.
For example, when conducting account monitoring, both the reason for the transaction and the expected transaction value or range help determine whether the activity is consistent with what was anticipated. Without this information, it becomes significantly harder to identify behaviour that may be unusual or suspicious.
Recently, we have heard commentary in the market suggesting that collecting this type of information may not be required. From a compliance perspective, this is concerning. In our experience working closely with supervisors, understanding the nature and purpose of transactions is a key expectation.
This is also reflected in AUSTRAC core guidance. The Initial Customer Due Diligence reform guidance notes that reporting entities must understand the nature and purpose of the business relationship, including the expected transaction frequency and volume.
While the guidance specifically refers to transaction frequency and volume, it does not explicitly reference transaction value. However, value is inherently connected to ongoing customer due diligence, transaction monitoring, and the identification of suspicious matter reports (SMRs).
One of the core obligations under AML/CTF frameworks is monitoring for unusual transactions, including those that are unusually large or complex.
Without understanding what a normal or expected transaction value looks like, it becomes difficult to determine whether a transaction is unusually large. Establishing an expected value or range allows organisations to compare actual activity against expected behaviour and identify transactions that may require further investigation.
Another trend we are seeing in the market is the increasing number of providers offering software-only solutions, often positioning technology as the complete answer to AML/CTF compliance.
Technology is important, but software alone does not create compliance.
Effective AML frameworks rely on a combination of systems, expertise, operational capability, and education. Without the right support and guidance, organisations can easily misinterpret regulatory expectations or fail to implement processes correctly.
Interestingly, we are now seeing some of these same providers begin introducing outsourcing services after previously suggesting that software alone was sufficient. This shift highlights an important reality: technology needs to be supported by experienced people and operational processes to deliver meaningful compliance outcomes.
At AMLHUB, we have built our service model around this principle.
Our outsourcing team is structured to provide consistent coverage across Australia and New Zealand, supported by teams operating from Brisbane and Auckland. The team operates across time zones and is designed to scale as demand grows, ensuring that clients continue to receive the same level of support regardless of growth in the market.
While some providers suggest that outsourcing models cannot consistently deliver the required level of quality, this often reflects their own challenges in building and maintaining high-performing teams. Our experience has been the opposite.
We have invested heavily in a platform and product that integrates directly with our operational processes and industry expertise, allowing our analysts to operate with a level of efficiency that is rarely seen in the market. As our platform, processes, and training continue to evolve, this capability only continues to strengthen.
Importantly, our outsourcing capability is already established and proven today. It remains a core component of how we support our clients.
We are also seeing a growing number of organisations in New Zealand transition to AMLHUB after experiencing limitations with other providers. Our reputation in the outsourcing space has been built on reliability and consistently delivering on what we promise to our clients.
With Tranche 2 reforms approaching, businesses that will fall within scope from 1 July should begin preparing now. AML/CTF obligations require more than simply adopting a piece of software, they require a clear understanding of regulatory expectations, strong operational processes, and the right expertise to support ongoing compliance.
At AMLHUB, our approach combines technology, operational capability, and ongoing education to ensure our clients are not only ready for the changes ahead, but supported as the regulatory environment continues to evolve.
For organisations currently reviewing how they will prepare for the July reforms, the most important question is not simply what system you use, but who is supporting you to ensure it works in practice.
If you would like to learn more about how AMLHUB supports Australian businesses preparing for Tranche 2 AML/CTF obligations, our team would be happy to speak with you.
Contact AMLHUB today to book a demo or discuss how we can help your organisation transition seamlessly into the new regime.