Tranche 2 extends Australia's AML/CTF obligations to designated non-financial businesses and professions (DNFBPs), including accounting firms, real estate agencies, and law firms. Obligations commence 1 July 2026, with enrolment opening 31 March 2026.

Tranche 2 primarily affects accounting firms, real estate agencies, law firms, and other professional service providers that deliver designated services as defined under the AML/CTF Act. If your firm provides services like managing client money, preparing financial statements, facilitating property transactions, or providing legal services, you likely have obligations.

Key obligations include: customer due diligence (CDD) and identity verification, ongoing risk assessment, suspicious matter reporting (SMR) to AUSTRAC, threshold transaction reporting (TTR) for cash transactions of $10,000 or more, record-keeping, and maintaining an AML/CTF program.

An SMR is a report filed with AUSTRAC when you form a suspicion that a matter may be related to money laundering, terrorism financing, or other criminal conduct. Importantly, 'tipping off' — informing the subject of the report — is a criminal offence under section 123 of the AML/CTF Act.

Sentine is a compliance workflow tool — it is not endorsed, approved, or certified by AUSTRAC. Sentine helps your firm structure its compliance processes and produce audit-ready evidence packs, but firms remain responsible for their own compliance decisions.

No. Sentine provides structured workflows that help demonstrate your firm's compliance procedures and decisions. It produces audit-ready evidence packs but does not guarantee compliance. Your firm's compliance officer must still exercise professional judgement.

Yes. All Sentine data is stored in Australian data centres. We understand the sensitivity of AML/CTF data and the regulatory requirements around data sovereignty.

SMR data is stored in a completely separate system from regular matter data. Only users with the AMLCO (AML/CTF Compliance Officer) role can access SMR information. No SMR indicators appear on shared dashboards, matter lists, exports, or notifications — this is a core architectural principle to prevent tipping-off.

Sentine attaches compliance obligations to individual Matters or Engagements, not just client records. This means each designated service engagement has its own scoping, risk assessment, evidence pack, and audit trail — reflecting how compliance actually works in practice.

Sentine supports safe harbour verification (AUSTRAC-described procedures for medium and lower risk customers), non-safe harbour verification, and manual verification with structured evidence capture. The platform uses a vendor-agnostic adapter pattern, currently supporting FrankieOne as the identity verification provider.

An evidence pack is a versioned, tamper-evident snapshot of all compliance decisions, documents, and verification results for a matter. Each pack is hashed for integrity verification and includes configurable redaction rules to control what appears in different export contexts.

Sentine is currently taking on new clients ahead of the 1 July 2026 commencement date. You can get started through our contact form.

Our Base plan starts at just $49/month and gives you full access to the AML program wizard, training register, and compliance preparation tools. It's the easiest way to get started before Tranche 2 obligations commence on 1 July 2026.

All plans include onboarding support to help your firm set up its AML/CTF program, configure workflows, and train your team on the platform. Professional and Enterprise plans include dedicated onboarding sessions.

Safe harbour refers to the verification procedures described by AUSTRAC for medium and lower risk customers. If your firm follows these described procedures, it can demonstrate it took reasonable steps to verify customer identity. Important: safe harbour does not mean immunity from compliance failures — it describes a procedure, not a guarantee.

If an automated verification check returns a 'refer' or 'fail' result, Sentine provides a structured manual verification fallback path. Your team can upload alternative documents and capture evidence manually, with the same level of documentation and audit trail as automated checks.

For entities (companies, trusts, partnerships), Sentine guides your team through identifying beneficial owners (individuals with 25% or more ownership) and controllers (trustees, directors, etc.). Each person identified can be verified through the same safe harbour, non-safe harbour, or manual paths. Where ownership information cannot be obtained, the system requires a documented reason.

ECDD is triggered when high-risk indicators are present in a matter — such as high-risk jurisdictions, complex ownership structures, PEP associations, adverse media, third-party payers, or unusual urgency. Sentine's risk wizard evaluates these factors and automatically opens ECDD cases when thresholds are met.

Source of funds (SOF) refers to the origin of funds used in a specific transaction — where the money for this particular engagement came from. Source of wealth (SOW) refers to the origin of a person's total financial standing — how they accumulated their overall wealth. Both may be required as part of ECDD.

Sentine's risk assessment wizard uses a multi-factor framework covering customer type, geographic risk, product complexity, delivery channel, and transaction patterns. The framework is designed to meet AUSTRAC expectations while capturing the rationale behind every risk decision.

Evidence packs can be exported as PDF (human-readable summary) or ZIP (PDF plus attachments index, file hashes, and selected supporting documents). Both formats include SHA-256 integrity hashes for tamper detection.

Default evidence packs exclude raw provider payloads, detailed sanctions hit information, and any SMR-related data. Your AMLCO can generate expanded 'sensitive packs' that include this information when explicitly needed, but the default export is always privacy-protective.

The AML/CTF Act requires records to be retained for 7 years from the date the relationship ends or the designated service is provided. Sentine tracks retention anchor dates and reasons for each matter, ensuring records are preserved for the required period.

Sentine calculates periodic refresh due dates based on risk rating — high-risk matters every 12 months, medium every 24 months, and low-risk every 36 months. Event triggers (ownership changes, new services, risk profile changes) can also prompt re-verification outside the scheduled cycle.

Several events can trigger re-verification: ownership or control changes, new designated services, changes in risk profile, scheduled periodic refreshes, or significant changes in client circumstances. Each trigger generates a new evidence pack version with a complete change trail.

Full transaction monitoring integrations are currently not included. Sentine focuses on decisioning, documentation, and evidence capture. For TTR obligations, staff can manually attest cash transactions of $10,000 or more within the matter workflow.

Sentine maps entity structures including trusts, corporate trustees, and layered ownership. For each trust, the system guides identification of trustees, settlors, appointors, and beneficiaries — with structured documentation for complex or multi-layered arrangements where information may be difficult to obtain.

Yes. Sentine supports multiple parties per matter with defined roles (vendor, purchaser, co-buyer, guarantor, etc.). Parties can be added or removed at any stage, and the system recalculates verification requirements when party configurations change.

When a cash component of a real estate transaction reaches $10,000 or more, Sentine provides a structured TTR capture workflow within the matter. The workflow captures all required transaction details, links the TTR record to the matter and parties, and stores the AUSTRAC submission reference.

Sentine includes privilege-aware workflows that let practitioners flag matters or documents as potentially subject to LPP. The system captures the privilege assessment and rationale while ensuring compliance obligations are still met. This helps law firms navigate the intersection of their professional privilege obligations and AML/CTF reporting requirements.

Yes. Sentine integrates trust account monitoring into matter workflows, tracking cash deposits and movements that may trigger TTR obligations. For law firms managing client trust accounts, the system provides structured workflows for documenting the source and purpose of trust account transactions.

Law firms often deal with multi-layered corporate structures, nominee arrangements, and complex trust deeds. Sentine supports mapping these structures with linked entity records, beneficial owner identification through multiple ownership layers, and structured documentation where ownership information is difficult to obtain or verify.