The hidden admin of Tranche 2: What your business should expect (and how to make it easier)
When people talk about Tranche 2, the conversation usually focuses on rules, risk and regulation. What doesn’t get nearly as much airtime is the day-to-day admin sitting underneath it that you need to be doing to ensure you actually comply. And that’s where we expect many businesses will feel the impact first.
The AML/CTF regulations (and thus compliance), is incredibly detailed, yet theoretical on paper. In practice this shows up as extra tasks, extra tracking, extra checks and extra records, layered onto your already busy days.
If you’re a real estate agency, law firm, conveyancing practice or accounting business, this article is about setting expectations. It is not meant to overwhelm you, but instead to make sure you’re not caught off guard when the new regulations kick off in July 2026. We’ll look at exactly what the hidden admin of Tranche 2 looks like, and why using the right technology will be the difference between coping… and actually feeling in control.
Tranche 2 compliance should be built into your workflow
From 1 July 2026, Tranche 2 brings new AML/CTF obligations to a wide range of professional services. On paper, those obligations look clear enough:
- Know your customer (KYC)
- Assess and manage risk (both in your business and over the course of the specific services you provide your clients)
- Monitor transactions and client activity
- Report when required
- Train staff - both initially, and ongoing, tailored to their specific roles
- Keep detailed records of all of these activities and how you carried them out
And behind each of those obligations, hides a trail of admin behind it. It’s dozens of small, repeatable actions, happening across multiple matters, clients and team members.
And that’s before you factor in reviews, audits, or regulatory requests!
Where the admin really shows up
1. Customer due diligence doesn’t stop at onboarding
Many Tranche 2 businesses already do some form of ID check on their clients. But the Customer Due Diligence (CDD) rules around this in the context of AML/CTF means many will need to go further than they currently are.
Admin you’ll now need to manage includes:
- Assessing and recording the reason for, and related risk of, the transaction
- Tracking when CDD was completed
- Recording how it was completed
- Storing evidence securely
- Refreshing information when circumstances change
- Applying enhanced due diligence (EDD) where risk increases
- Keeping a clear audit trail of decisions
Multiply that across every new client, as well as existing ones (known as a pre-commencement customer, with a different CDD process to follow), and the admin adds up quickly.
Remember, if you’re currently doing some kind of ID verification on your clients manually or via a service like Australia Post, this won’t be sufficient to comply with CDD requirements under the new Tranche 2 obligations.
2. Ongoing monitoring means ongoing record-keeping
We’ve said it before, and we’ll say it again: AML/CTF isn’t a “set and forget” obligation. You’re expected to monitor clients and transactions over time. That creates admin around:
- Reviewing changes to client behaviour
- Documenting why something was or was not suspicious
- Escalating concerns internally
- Tracking outcomes and follow-up actions
Even deciding not to lodge a suspicious matter report creates paperwork. AUSTRAC still expects to see how you reached that decision.
3. Reporting isn’t hard, but it can be time-consuming
Suspicious Matter Reports (SMRs), Threshold Transaction Reports (TTRs) and other notifications all come with deadlines. Behind each report sits admin like:
- Collecting supporting information
- Linking it to the relevant client or transaction
- Recording who reviewed it and when
- Keeping evidence for seven years
Without systems in place, reporting becomes reactive, (and often stressful).
4. Governance and oversight create “invisible” admin
Tranche 2 also introduces management-level obligations that don’t show up in day-to-day client work but still require time and attention. We’re talking about things like:
- Appointing and supporting a Compliance Officer
- Documenting oversight and decisions
- Reviewing AML/CTF programs and risk assessments
- Preparing for independent reviews
- Responding to guidance updates
This is the kind of admin that often falls to business owners or practice managers, on top of everything else they already do.
5. Training has to be tracked, not just delivered
It’s not enough to say “we trained our staff”. You’ll need to:
- Deliver role-appropriate training
- Keep records of attendance
- Refresh training regularly
- Show how training aligns to your risks
That’s more admin, especially in businesses with casual staff, turnover, or multiple offices.
Why this feels familiar (and why that matters)
Here’s where Tranche 2 starts to look a lot like something you already understand. Think about practice management software. You could manage your matters, sales or client work manually. Email folders, spreadsheets, paper files, sticky notes and reminders. But you don’t, because it’s inefficient, risky and exhausting. Instead, you use software because:
- Everything lives in one place
- Tasks are tracked automatically
- Records are easy to find
- Work can be easily handled across the team
- Errors are reduced
- You can scale without losing control
AML/CTF admin works exactly the same way.
Technically, yes, you could manage it all manually…
- Tracking checks
- Updating records
- Monitoring changes
- Remembering what to report and when
- Keeping evidence for years
But just because you can… doesn’t mean you should. And this is where the right AML/CTF software can save you hours and hours of manual admin time, and remove the stress and overwhelm that comes with meeting new compliance obligations.
The emotional cost of “manual compliance”
This is where the admin problem becomes more than just time. Manual compliance leads to:
- Constant mental load (“Have we done this?”)
- Fear of missing something important
- Inconsistent processes between staff
- Scrambling when a regulator asks for evidence
We’ve seen it before in other spaces, where compliance becomes something you worry about, not manage. That’s the difference between coping and confidence.
And it’s why Tranche 1 businesses rely on technology. Not because they have to, but because it makes compliance sustainable.
How technology makes the hidden admin manageable
When AML compliance is built into your workflow, rather than bolted on as an after-thought, the admin changes completely. Technology helps by:
- Centralising CDD, monitoring, reporting and records
- Automating routine tasks and reminders
- Creating audit trails automatically
- Reducing duplication and rework
- Giving team leaders, and the Compliance Officer visibility without micromanagement
Just like practice management software, good AML tech doesn’t replace your judgement, it supports it.
Where easyAML fits (without the sales pitch)
In the final stretch toward 1 July 2026, many Tranche 2 businesses will ask the same question: “How do we do this properly without drowning in admin?”.
easyAML was built to answer exactly that.
In the same way your practice management system keeps client work organised, easyAML helps manage the entire AML lifecycle:
- Customer due diligence beyond ID checks (including PEPs and Sanctions screenings)
- Ongoing monitoring
- Pre-drafted reporting workflows
- Secure, long-term record storage
- Engaging training modules for your entire team
- Clear governance and audit trails
For businesses that don’t want compliance living in spreadsheets and inboxes, it provides structure, clarity and breathing room. easyAML takes the admin out of people’s heads and puts it where it belongs: into a system designed for the job.
The practical reality of Tranche 2
The Tranche 2 admin is real. It’s ongoing. And it will touch almost every part of your business. The good news? This isn’t new territory. You already know how to handle complexity. After all, you do it every day with your current work, by using the right tools.
AML/CTF compliance works the same way.
With the right technology, the hidden admin becomes manageable. Without it, compliance becomes a constant source of friction.
Want to see what that looks like in practice?
Join one of our upcoming easyAML webinars for a clear, practical walkthrough of what the admin behind Tranche 2 actually looks like and how our end-to-end compliance technology simplifies it and fits into your everyday workflows.
You’ll also get a chance to see the platform in action, so you can decide whether it’s the right tool for your business.
Because compliance shouldn’t feel harder than the work you already do. Instead it should feel like it belongs right alongside it.