Can my CRM handle AUSTRAC Tranche 2?

If you've heard from a peer or seen an announcement that "your CRM now does AML compliance," the first thing to do is check what that actually means.

Some CRM providers have added identity verification or compliance-adjacent features ahead of the 1 July 2026 deadline. That is genuinely useful. But identity verification is one step of customer due diligence — and AUSTRAC requires a lot more than that.

The fastest way to avoid this problem

If you want to get your AML/CTF obligations sorted without investigating your CRM's compliance capabilities, AML Simple works standalone — no CRM connection required.

Sign up (around 2 minutes), complete the AUSTRAC Enrolment Cheat Sheet at /enrolment-cheatsheet (around 5 minutes), and run the AML/CTF Program Generator at /program/generate (around 15 minutes). Your program is done. Everything else — client verification, sanctions screening, training records, SMR drafting — runs inside AML Simple alongside whatever CRM you already use.

If you'd rather evaluate your existing options first, read on.

What AUSTRAC actually requires

The AML/CTF Amendment Act 2024 brings real estate agencies under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 from 1 July 2026.¹ The full set of obligations includes:

AUSTRAC enrolment — register your business before 29 July 2026²
AML/CTF program — a documented risk assessment, policies, and procedures specific to your agency³
Compliance officer appointment — at senior management level, documented
Customer due diligence (CDD) — identity verification, PEP screening, sanctions screening before providing designated services
Ongoing CDD — throughout the business relationship
Staff training — documented training on AML/CTF risks for all relevant staff
Suspicious Matter Reports (SMRs) — filed with AUSTRAC when triggered
Threshold Transaction Reports (TTRs) — for cash or physical currency transactions of A$10,000 or more
Annual Compliance Report — first period: 1 January to 31 March 2027
Seven-year record keeping — all CDD records, program documents, and reports⁴

That is ten distinct obligations. Identity verification alone addresses one of them partially.

For the complete breakdown, see: AUSTRAC Tranche 2 for Real Estate: The Complete Guide

The checklist: what to ask your CRM

If your CRM provider says they have an AML compliance solution, ask these questions:

Obligation	Question to ask	What to look for
AML/CTF program	Does the software generate or store my agency's AML/CTF program document?	A structured program document, not just a template PDF
Risk assessment	Does it walk me through a risk assessment for my agency?	Agency-specific risk factors, not a generic questionnaire
Compliance officer	Does it record the appointment of my compliance officer?	A documented record, not just a name field
CDD — identity verification	Does it verify client identity with document capture and biometric check?	Confirmation of what identity documents are accepted
CDD — PEP screening	Does it screen clients against Politically Exposed Persons lists?	Daily-updated PEP list coverage
CDD — sanctions screening	Does it screen against UN and DFAT sanctions lists?	Daily-updated sanctions list coverage
Ongoing CDD	Does it support ongoing monitoring of existing clients?	Alerts or scheduled re-verification
Staff training	Does it provide staff training and keep completion records?	A training module with a completion log
SMR drafting	Does it help draft Suspicious Matter Reports and file them with AUSTRAC?	Structured SMR workflow, not just a note-taking field
TTR tracking	Does it track and report threshold transactions?	A$10,000+ cash transaction logging
Annual Compliance Report	Does it help complete the AUSTRAC Annual Compliance Report?	Guided report workflow or data export
7-year record keeping	Does it store all records in Australia for at least seven years?	Data residency confirmation (AU)

A "yes" to all twelve means the CRM solution genuinely covers your full obligation set. A "yes" to some means you have partial coverage and will need to fill the gaps elsewhere.

Common gaps to watch for

Program and risk assessment. Many tools that add identity verification do not include an AML/CTF program generator. The program is the backbone of your obligations — without it, you have a process but no documented framework.

SMR and TTR support. Reporting obligations are often omitted from CRM-adjacent compliance tools. Check whether your CRM actually files reports with AUSTRAC or just helps you draft notes.

Training records. AUSTRAC requires documented evidence that your staff have received AML/CTF training. An email sent out is not a training record.

Data residency. AUSTRAC has not mandated Australian data residency, but it is standard practice for compliance records to be stored in-country. Confirm where your data is held. AML Simple stores all data in Sydney (AWS ap-southeast-2).

If your CRM doesn't cover all of it

You have two options:

Use AML Simple as a standalone platform — sign up, complete your program, and run your compliance workflow inside AML Simple. Your CRM stays as it is; no integration required.
Use a combination — if your CRM handles identity verification well and you want to keep that workflow, use AML Simple for the program, training, SMR drafting, TTR tracking, and annual reporting. They operate independently.

Neither approach requires you to change your CRM. See: Your AML compliance tool doesn't have to come from your CRM

Start free at amlsimple.com. Foundation tier is free, up to five clients. Paid plans from A$79/month, with a 14-day free trial.

Footnotes and sources

Disclaimer: AML Simple is a compliance workflow tool, not a source of legal advice. This article provides general information about AUSTRAC's Tranche 2 requirements. For advice specific to your agency, consult a qualified AML compliance professional.

Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth). legislation.gov.au ↩
AUSTRAC, Tranche 2 key dates, austrac.gov.au. Enrolment deadline 29 July 2026. ↩
AUSTRAC, AML/CTF program requirements for real estate agents, austrac.gov.au. See also AUSTRAC Real Estate Program Starter Kit. ↩
AML/CTF Act 2006, s 112: records must be kept for seven years from the date the record was made. ↩