Do I need to use an expensive AML/CTF provider to comply with Tranche Two laws?
No. There are no specific sections under the Anti-Money Laundering and Counter-Terrorism
Financing 2006 (as amended) or supporting Rules that require you to use a particular
provider or to choose a high cost compliance solution. The law sets standards, not price
points. What matters is that your business follows a structured and documented AML/CTF
program that meets AUSTRAC requirements.
A compliant program must include a business risk assessment, policies and controls, customer
due diligence, ongoing monitoring, reporting and record keeping. It must reflect the size,
nature and risk profile of your business. The legislation is outcome focused. It does not
mandate any specific vendor, platform or cost.
For many Tranche Two businesses, large expensive providers are unnecessary. High subscription
fees are usually driven by overheads, not by legal need. Flagship AML offers the same
essential compliance functions for a fraction of the cost because our processes are highly
automated and our team is lean and legally trained. Our pricing reflects efficiency, not
shortcuts.
If your AML/CTF program is well designed, risk based and properly maintained, you meet the
requirements regardless of whether you pay $499 dollars per year or $11,999 dollars per
year. Compliance quality is measured by effectiveness, not by expense.
When do Tranche Two obligations begin?
AUSTRAC enrolment opens on 31 March 2026 and closes on 29 July 2026. Compliance obligations
apply from 1 July 2026.
Who is Flagship AML?
Sun Card Pty Ltd trading as Flagship AML is a 100% Australian owned and operated Anti Money
Laundering and Counter Terrorism Financing platform.
Are you affiliated with any Government agency?
No.
Who is it designed for?
The platform supports all Tranche Two professions, with a strong focus on helping small
Australian businesses with less than 20 employees navigate the new AML laws with clear and
practical guidance. The platform is suitable for Tranche Two businesses including lawyers,
conveyancers, accountants, tax agents, real estate agents, precious metals and stone dealers
and trustee or company service providers.
Will you collect or store any client information?
Our platform is designed to support your AML/CTF obligations by enabling you to complete your
own due diligence. We do not access or use your client information for any purpose other
than by providing the service.
You must save all the reports downloaded using our platform, as this information will not
save in our system. This is designed to protect client and customer confidentiality.
Information you enter may be temporarily processed or held on our secure servers for system
functionality. Where this occurs, it is protected by strong encryption and strict access
controls. The information is removed once it is no longer required for the operation of the
tool. We do not view, use or retain client and customer information beyond what is necessary
to deliver the service, and we do not store client information in a form that can be
accessed or read by us.