AUSTRAC’s Expectations
If you exchange virtual assets and money, move value across borders, safeguard digital assets or participate in token offers or sales, you are squarely in AML/CTF territory and must treat travel‑rule and CDD obligations as core product requirements, not add‑ons.
From 1 July 2026, AUSTRAC expects you to:
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AML Smart Guard is the complete solution. From getting AUSTRAC ready, to client onboarding, ongoing monitoring and reporting, AML Smart Guard offers intuitive design, automation, full support, training and a knowledge centre in one fully compliant package.
AML Smart Guard empowers all Tranche 2 affected businesses to own their AML/CTF risk mandate through our experience, our partnerships, trusted platform and delivery know how; we provide the people, processes and technology to deliver your AML program.
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AML Smart Guard’s Australian leadership team have decades of career long experience in risk and compliance solutions delivered and supported for both Australian and international banks and financial services firms.
Tranche 2 is an Australian problem. Our people live in the same regulatory environment you do, follow AUSTRAC’s updates as they land, and work every day with real estate, legal, accounting, corporate, gaming and digital‑asset clients facing the 1 July 2026 deadline.
We combine local AML/CTF expertise with practical experience inside Aussie firms, so when you call, you’re talking to someone who understands how your trust account works, how your practice software behaves, and what AUSTRAC is actually likely to look for in your sector.
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Frequently
asked questions
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Build an AML/CTF program around how you actually move value and interact with other VASPs and banks. Key priorities include:
- Pin down your designated services:
- Confirm exactly which activities you provide – crypto↔fiat exchange, crypto↔crypto exchange, custodial wallets, sending/receiving virtual‑asset transfers, token offers, stored‑value wallets or remittance/payment services – and map each to the relevant AUSTRAC items.
- Run a product‑level ML/TF risk assessment:
- Assess risk by product (on‑ramp/off‑ramp, P2P transfers, cards/wallets), customer type, jurisdictions, assets traded and delivery channels (API, app, exchange, OTC). Use this to drive your risk rating logic, CDD depth and monitoring rules.
- Design strong digital CDD and ECDD:
- Define how you will verify customers and beneficial owners online (KYC data, liveness, biometrics, document checks), when to ask for source‑of‑funds/wealth, and what extra steps you take for higher‑risk profiles (PEPs, high‑risk countries, mixers, privacy tools).
- Build travel‑rule compliance into your tech:
- Plan how you will collect, validate, transmit and store originator and beneficiary information for qualifying virtual‑asset transfers, and what you do if a counterparty VASP cannot securely comply.
- Set clear monitoring and escalation rules:
- Define scenarios that should trigger alerts: structuring across wallets, rapid in‑and‑out movements, chain‑hopping, use of high‑risk or sanctioned services, unusual card or wallet behaviour. Tie each to escalation paths and SMR decision criteria.
- Governance, registration and review:
- Plan for VASP registration/enrolment, appoint an AML/CTF compliance officer, get the program approved by senior management, and schedule regular tuning and independent review.
Done well, your program becomes part of the product as built into onboarding, transaction flows and APIs, rather than bolted on as an afterthought.
For digital asset and payments firms, AUSTRAC wants to see that you are properly registered, have a fit‑for‑purpose AML/CTF program, and that CDD and monitoring are embedded in your product, not running off to the side.
- Confirm you are a VASP / payment reporting entity:
- Work out which of your activities are designated services: exchanging virtual assets and money, virtual‑asset↔virtual‑asset exchange, custody, sending/receiving virtual‑asset transfers, or providing financial services connected to token offers/sales.
- Include any remittance or payment services (cards, wallets, pay‑in/pay‑out rails) already caught under existing AML/CTF rules.
- Register/enrol with AUSTRAC:
- Apply for registration/enrolment as a virtual‑asset service provider and/or remittance/payment service provider through AUSTRAC’s online portal, providing ownership, control, business‑model and key‑person details.
- Expect AUSTRAC to look closely at fitness and propriety, governance and the nature of your products before accepting or renewing registration.
- Build a product‑driven AML/CTF program:
- Draft Part A (risk assessment, governance, monitoring, reporting, training) and Part B (customer identification and verification) tailored to your products, customers, jurisdictions and technology stack.
- Explicitly address virtual‑asset risks such as anonymity‑enhancing tools, mixers, high‑risk exchanges, DeFi interfaces and cross‑chain bridges.
- Wire the program into your stack:
- Implement KYC/CDD, sanctions/PEP screening, risk‑rating and travel‑rule data capture via APIs and back‑office workflows, so controls sit inside your apps, exchanges, wallets and payment flows.
- Configure transaction‑monitoring rules, case‑management and SMR workflows before go‑live, and test them with realistic scenarios.
Customer due diligence (CDD) in production:
- Onboarding: Every new customer (and beneficial owner) goes through digital ID verification, sanctions/PEP screening and risk‑rating before accessing higher‑risk services (for example, higher limits, fiat off‑ramp).
- Risk‑based tiers: Higher‑risk customers (PEPs, high‑risk jurisdictions, complex structures) face stronger verification and lower default limits, plus mandatory source‑of‑funds/wealth checks.
- Lifecycle events: CDD is refreshed when key events occur – large limit increases, new products (like OTC access), changes of ownership, or negative news hits.
Ongoing monitoring:
- Transaction‑pattern analytics: The system watches for structuring across accounts, rapid in‑and‑out movements, use of mixers or privacy coins, chain‑hopping, interactions with high‑risk VASPs or sanctioned addresses, and unusual card/wallet behaviour.
- Travel‑rule compliance: For qualifying transfers, originator and beneficiary information is collected, screened, transmitted and stored, and alerts are raised where counterparty VASPs do not provide adequate data.
- Alerting and escalation: Analysts receive risk‑scored alerts with sufficient context, escalate genuinely suspicious activity, and decide whether to file SMRs, apply enhanced CDD, restrict services or exit the customer.
- Audit‑ready records: The platform logs every CDD step, decision and alert outcome, and retains them for at least seven years so AUSTRAC can see exactly what you did and why.
In short, for digital asset and payments firms, AUSTRAC enrolment and build is about proving you understand your specific ML/TF risks and have coded them into your products; “live CDD and monitoring” is that logic working continuously in the background on every user and every transaction.
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