A study involving real estate professionals, legal advisors, and financial consultants—now covered by the Tranche 2 reforms, shows a stark divide between self-assessed readiness and actual adherence. These regulations, effective from July 1, 2026, expand obligations beyond banks, casinos, and foreign exchange providers, which were required to comply beginning in March 2026.
Among businesses employing 20 or fewer staff, confidence in meeting the rules is lowest. Kaan Yuksel, Founder and MD at AML compliance specialist Visibl, noted that the legislation “honestly feels more complex for small and medium businesses than it does for the banks already in Tranche 1.” An anonymous representative from an accounting firm stated the framework is poorly suited for small practices, arguing that compliance demands excessive procedures for clients posing minimal risk. Another respondent highlighted the unnecessary administrative strain on micro-enterprises lacking the resources of larger firms.
The survey revealed that 65.6% of businesses think they would succeed in an AUSTRAC compliance audit, yet only 34.4% would fully satisfy all criteria when evaluated across governance frameworks, risk assessments, staff training, and daily operations. This discrepancy, a 31-point difference—exposes a serious gap between self-perception and actual performance.
A critical oversight involves identity verification. 75.4% of respondents mistakenly assume that verification of identity (VOI) checks alone fulfill all anti-money laundering obligations. However, over half neglect additional mandatory screenings, including sanctions lists, politically exposed persons (PEPs), and beneficial ownership reviews for companies and trusts. Consequently, 42.6% of businesses overestimate their compliance levels.
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Confusion persists over VOI requirements. Emmanuel Michael, founder of buyer’s agency Investor Mate, explained the misunderstanding: I completely understand why people think VOI is all that’s required. Jesselyn Dang, a business transformation manager at accounting firm HK Partners, noted that while core obligations may be met, ongoing compliance remains unclear for many operators.
Small businesses are not only struggling; they are advocating for systemic improvements. A recurring demand is for a government-endorsed digital identity system to simplify verification across transactions. Currently, a single property purchase often forces clients to undergo identity checks with five separate entities, including financial institutions, mortgage brokers, real estate agents, solicitors, and accountants. A token-based system, where verification is conducted once and reused, could eliminate redundancy and enhance efficiency.
Kaan Yuksel, Founder and MD at Visibl, said, “VOI (verification of identity) is only the first part of initial due diligence, and a tokenised system would be a huge efficiency gain within Australia.” He added that it does not solve AML on its own as identity checks alone will not satisfy AML requirements initially or ongoing.
