Frequently Asked Questions About AML Compliance & Tranche 2

General

VISIBL is a specialist AML compliance platform for Australian businesses. It combines digital onboarding, verification, AML/CTF risk assessments, monitoring, reporting and recordkeeping with certified AML specialists so your compliance is defensible under Tranche 2.

DIY tools typically provide templates and checklists and leave interpretation to your team. VISIBL embeds specialist-reviewed workflows, risk logic and documentation so that day-to-day tasks are automated but the underlying program remains robust and audit-ready.

Traditional consultants work in projects and point-in-time reviews. VISIBL pairs that specialist expertise with an always-on platform so your policies, risk assessments, verifications and training sit in one system instead of static documents and spreadsheets.

VISIBL is designed for Tranche 2–impacted businesses such as real estate agencies, buyers agents and related professional services firms that need a practical way to meet AML obligations without adding a full-time compliance team.

Tranche2 & Regulation

Tranche 2 is the expansion of Australia’s AML/CTF regime that brings non‑financial professions, including real estate, into scope for AUSTRAC regulation. It introduces obligations for customer due diligence, monitoring, reporting and recordkeeping.

Key dates are still being finalised by government, but the current proposals target obligations commencing from 1 July 2026. VISIBL is built to help you prepare well before enforcement begins.

Agencies that do not comply may face AUSTRAC enforcement action, including audits, enforceable undertakings and significant civil penalties for both the firm and responsible individuals.

Most residential and commercial real estate agencies that handle high‑value property transactions will be in scope. Exact coverage depends on the final legislation and your business model.

Yes. Regulated entities must implement and maintain a documented AML/CTF program and ML/TF risk assessment that are tailored to their specific risks, regularly reviewed and kept up to date.

Fit for Real Estate

Real estate can be used to launder proceeds of crime or conceal beneficial ownership. Tranche 2 extends AML/CTF obligations so agencies help prevent and detect this activity.

Yes. VISIBL is built with use cases for buyers agents and other intermediaries, including workflows tuned to how you engage and verify clients.

Commercial and mixed‑use scenarios often involve more complex structures. VISIBL helps you capture ownership details, assess risk and maintain clear documentation.

Fit for Accountants

Yes. Accountants who provide services including formation of companies or trusts, assisting with buying or selling entities, or managing client funds in certain contexts are in scope. This captures a broad range of accounting practices, including tax agents, bookkeepers and business advisors providing designated services. If you are unsure whether your practice is captured, Visibl specialists can help you assess your obligations.


AUSTRAC focuses on what are called 'designated services'. For accountants, these typically include acting as a formation agent for companies or trusts, providing registered office or nominated director or company secretary services, and managing client money or assets in certain circumstances or assisting with the purchase and sale of companies or trusts. Not every service an accountant provides will be captured — Visibl can help you map which parts of your practice are in scope.

From 1 July 2026, you must verify clients before providing designated services. For existing clients, AUSTRAC expects a risk-based approach — if their ownership or identity details change, there is a red flag, or if you have suspicions, you must verify them. Visibl supports both new onboarding and remediation workflows.

Visibl's KYB (Know Your Business) capability is built for complex structures. It supports identification of beneficial owners across layered entities, trusts, and corporate groups — which is particularly relevant for accounting clients with sophisticated structures.

Yes. Visibl's Professional and Plus tiers are designed for higher volumes, with bulk onboarding workflows, included KYC/KYB check allowances and reduced per-check rates at higher tiers. Multi-partner firms can also use role-based access to manage compliance across teams.

Under AML/CTF obligations, you cannot provide a designated service to a client you have not been able to verify which is important for maintaining an audit trail if AUSTRAC ever reviews your records.

Visibl is designed to complement your existing workflows. If you have questions about connecting Visibl with your current practice management or document systems, speak with the Visibl team.

When electronic verification fails Visibl is designed to allow you to manually verify your customers. Visibl Consultants can provide guidance on the documentation required to verify that’s aligned to your AML/CTF Policy. You can then manually verify and track this action within the Visibl platform ensuring you have an audit trail with decisions and actions that align to your AML/CTF Policy.  

Fit for Law Firms

Yes. Legal practitioners and conveyancers providing services related to real property transactions, managing client funds through trust accounts, forming companies or trusts, or acting as a registered office, among other designated services are in scope. The obligations apply from 1 July 2026.

AML/CTF obligations attach to specific 'designated services', not your entire practice. For law firms, this typically captures conveyancing and property matters, trust and estate work involving entity formation, assisting with sales, mergers and acquisitions, raising equity or debt and trust account services. Visibl specialists can help you identify which practice areas and services are captured.

Trust account obligations under state law coexist with Tranche 2 AML/CTF requirements. Visibl focuses on the AML/CTF layer — client verification, risk assessment, record keeping and reporting — and is designed to complement, not replace, your existing trust account compliance processes.

Visibl includes Enhanced Due Diligence (EDD) workflows for higher-risk profiles, including foreign nationals, politically exposed persons (PEPs), non-resident entities and complex ownership structures. International sanctions, PEP and adverse media screening is built in.

Yes. Conveyancers are explicitly captured under Tranche 2 and Visibl supports their specific workflows — including fast property settlement timelines, vendor and purchaser verification, and audit-ready records for each transaction.

Visibl allows compliance records to be linked at the matter or transaction level, not just the client level. This is important for law firms and conveyancers where the same client may be involved in multiple transactions with different risk profiles.

Visibl produces a tailored, written AML/CTF Program validated by certified AML specialists. This includes your ML/TF risk assessment, policies and procedures, monitoring and reporting frameworks, and training records — all in audit-ready format aligned to AUSTRAC expectations.

Yes. Visibl's governance dashboards, role-based access and network-level reporting are suited to firms operating across multiple offices, practice groups or brands. Compliance oversight can be centralised while individual offices or fee earners maintain their own workflows.

Product / Platform

VISIBL helps you enrol with AUSTRAC, build and maintain your AML/CTF program, run risk‑based customer due diligence, monitor clients and transactions, manage training and keep structured, audit‑ready records in one place.

Yes. VISIBL can support digital KYC and KYB verification using approved data sources, with results and evidentiary trails stored against the client record.

VISIBL helps you triage and document suspicious matters so that when you need to lodge an SMR you have a clear, defensible record of how you reached that decision.

Yes. The platform retains key actions, decisions and verification evidence so you can demonstrate your compliance position during an AUSTRAC review or internal audit.

VISIBL can support role‑based training by tracking which staff have completed required modules and by surfacing policy‑aligned guidance inside day‑to‑day workflows.

Yes. VISIBL is designed for groups and networks, with the ability to centrally define programs and reporting while still giving local offices views of their own obligations.

Specialists & Defensibility

Certified specialists help design and review your AML/CTF program and risk assessment so they are aligned with AUSTRAC expectations, not just generic templates. That improves defensibility if your program is ever challenged.

Yes. VISIBL’s specialist team can work with you to configure a documented program and risk assessment that reflect your actual business, then operationalise it in the platform.

For complex clients, unusual structures or higher‑risk scenarios, the specialist team can provide guidance so you are not left guessing how to interpret your obligations.

Pricing & Commercial

VISIBL typically offers subscription plans sized to your office count and usage, with transparent pricing published in advance so you can budget and compare to internal costs.

Indicative plan pricing is available on our website. Larger networks and multi‑office groups can request a tailored proposal based on their footprint and risk profile.

Implementation & Support

Most firms can be onboarded in a matter of weeks, depending on how quickly we can gather information about your business and existing controls.

No. VISIBL is designed so operational staff can follow guided workflows while specialists handle the complex policy and regulatory interpretation in the background.

Yes. VISIBL can be paired with internal training initiatives so staff understand both the platform and their specific AML responsibilities.

Data, Security & Privacy

Data is stored in secure, region‑appropriate infrastructure with controls aligned to modern security practices. Specific hosting details can be shared as part of onboarding.

Retention settings are designed to meet or exceed AML/CTF requirements, typically at least seven years, while supporting your internal information governance policies.

Yes. VISIBL supports role‑based access so staff only see the data and workflows necessary for their role, reducing operational risk and improving privacy.

Legal & Risk

No technology can guarantee compliance. VISIBL is designed to make it much easier to implement, evidence and maintain a compliant program, but you remain responsible for how the system is used in your business.

AUSTRAC does not certify specific vendors. VISIBL is built by specialists who closely follow regulatory guidance so the platform aligns with current expectations.

Yes. VISIBL supports central oversight with local execution, making it suitable for groups that need consistent standards but flexible, office‑level operations.

The platform can help you generate structured, repeatable reporting so boards and senior management have visibility over AML risk, issues and trends.

VISIBL is designed so networks can manage programs across multiple brands or offices while still segmenting data appropriately and surfacing local responsibilities.