Tranche 2 AML/CTF Compliance for
Accounting Firms
Sentine provides the definitive AML/CTF Program template and guided scoping workflows for CA and CPA firms. Scale your Tranche 2 compliance without the manual overhead of spreadsheets.
What Makes Tranche 2 Hard for Accounting Firms
Complex structures, multiple services, and nuanced scoping — these are the real challenges your firm faces.
Complex Trust & Entity Structures
Accounting clients often operate through layered trusts, company structures, and partnerships. Identifying and verifying beneficial owners across these arrangements is time-consuming and error-prone without a structured process.
Multiple Designated Services Per Client
A single client may engage your firm for tax planning, financial statement preparation, and trust administration — each a separate designated service with its own compliance obligations. Tracking these at the client level misses critical detail.
Scoping Confusion
Determining which services are in-scope under Tranche 2 and which are out-of-scope is one of the biggest challenges for accounting firms. Get it wrong, and you risk either over-compliance costs or regulatory gaps.
Beneficial Owner Identification
Trusts with multiple classes of beneficiaries, corporate trustees, and layered holding companies make beneficial owner identification genuinely difficult. Manual processes frequently miss controllers or fail to document the reasoning behind identification decisions.
How Sentine Helps
Purpose-built workflows that address each challenge accounting firms face under Tranche 2.
Matter-First Approach for Multiple Services
Each designated service engagement becomes its own Matter with dedicated scoping, risk assessment, and evidence trail. When a client has three in-scope services, you create three Matters — each with its own compliance lifecycle. No obligations fall through the cracks.
- Create separate Matters for each designated service engagement
- Link multiple Matters to the same client without conflating obligations
- Track each Matter's compliance lifecycle independently
- Full audit trail per engagement, not just per client
Entity Structure Mapping
Sentine helps your team systematically capture and document complex entity structures. Record companies, trusts, partnerships, and their relationships — then identify beneficial owners and controllers with a guided workflow that captures your reasoning at every step.
- Map companies, trusts, and partnerships with their interrelationships
- Identify beneficial owners using 25% ownership threshold tracking
- Record controllers, trustees, and appointors for trust structures
- Document the reasoning behind every identification decision
Guided Scoping Wizard
Stop guessing what is in-scope. Sentine's scoping wizard walks your team through the designated service definitions for accounting firms, helping you determine which client engagements trigger Tranche 2 obligations and which do not — with a documented rationale for each decision.
- Vertical-specific designated service definitions for accounting
- Step-by-step scoping questions for each engagement type
- Clear in-scope / out-of-scope determination with recorded rationale
- Re-scoping workflow when engagement terms change
Safe Harbour Verification Guidance
For medium and lower risk customers, Sentine guides your team through AUSTRAC-described safe harbour verification procedures. For higher risk or non-standard situations, structured non-safe harbour and manual verification paths ensure every customer is verified with full evidence capture.
- Guided safe harbour procedure for eligible customers
- Non-safe harbour verification path with structured documentation
- Manual verification fallback with evidence upload and attestation
- Verification method path recorded for every customer (safe harbour, non-safe harbour, or manual)
Risk Assessment with ECDD Triggers
Sentine's guided risk assessment wizard captures multi-factor risk ratings for every Matter. When high-risk indicators are identified, Enhanced CDD workflows activate automatically — including source of funds, source of wealth, and senior management sign-off requirements.
- Multi-factor risk scoring framework tailored to accounting engagements
- Automatic ECDD triggers when high-risk indicators are detected
- Structured source of funds and source of wealth documentation
- Senior management approval routing for high-risk matters
Audit-Ready Evidence Pack Generation
Every decision, verification, and risk assessment is captured in a versioned, tamper-evident evidence pack. When you need to demonstrate compliance — whether for internal review, external audit, or regulatory inquiry — Sentine produces a complete, hashed evidence snapshot with configurable redaction rules.
- Versioned evidence packs with SHA-256 integrity hashing
- Configurable redaction rules to control sensitive information in exports
- Complete decision trail: decision, rationale, timestamp, and approver
- Export-ready snapshots that can be produced in minutes, not days
Use Case: New Trust Client Engagement
Follow a realistic engagement through the full Sentine workflow.
Client Onboarding & Scoping
A new client approaches your firm to manage their family trust's annual tax obligations and prepare financial statements. Your team creates a new Matter in Sentine and uses the scoping wizard to determine which services are designated services under Tranche 2. The wizard identifies that both the tax return preparation and financial statement services are in-scope, so two separate Matters are created — each with its own compliance obligations.
Entity Structure & Beneficial Owner Mapping
The family trust has a corporate trustee (a proprietary company) and four individual beneficiaries across two classes. Your team maps the entity structure in Sentine, recording the trust, the corporate trustee, and each beneficiary. The system guides the team through beneficial owner identification — flagging the individual who controls the corporate trustee as a beneficial owner and documenting the reasoning for each identification decision.
Identity Verification
Sentine determines the appropriate verification path based on the initial risk indicators. For the individual beneficial owners, safe harbour verification is available — the system guides your team through the AUSTRAC-described procedure. For the corporate trustee, a non-safe harbour path is used with ABN verification, ASIC extract, and director identification. All verification results and source documents are captured against the Matter.
Risk Assessment & ECDD Check
The guided risk assessment wizard evaluates the Matter across multiple risk factors. The trust structure and one beneficiary's overseas residency flag the Matter as requiring closer attention. The risk rating is recorded with full rationale. In this case, the overall rating does not trigger ECDD, but the system documents the factors considered and the reasoning for the final rating — providing a clear record if the assessment is ever questioned.
Evidence Pack & Ongoing Monitoring
With scoping, verification, and risk assessment complete, Sentine generates a versioned evidence pack for each Matter. The packs include every decision, document, verification result, and risk assessment — hashed for integrity and ready for review. As the engagement continues, any changes (new beneficiaries, updated risk factors, annual reviews) are captured as new evidence pack versions with a full change trail.
Ready to Streamline Your Firm's Tranche 2 Compliance?
Join accounting firms across Australia preparing for 1 July 2026 with a structured compliance workflow built for complex client structures.
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