Implementation Plan
Structured implementation timeline for Tranche 2 compliance, with enrolment opening 31 March 2026 and obligations applying from 1 July 2026
What You Get
A comprehensive roadmap to guide your Tranche 2 implementation
The Implementation Plan provides a structured timeline for reporting entities where system changes are unlikely to be achieved before obligations apply. It breaks down the compliance journey into manageable phases with clear milestones and checkpoints.
This is particularly valuable for organisations that need to coordinate multiple stakeholders, implement new processes, and ensure nothing falls through the cracks as key dates approach.
Key Features
Phase-Based Timeline
Implementation broken into clear phases: Planning, Document Development, Internal Review, Lawyer Consultation, System Integration, Training and Final Enrolment.
Critical Milestones
Key dates and checkpoints to keep your implementation on track, with buffer time built in for unexpected delays or additional review cycles.
Task Checklists
Detailed task lists for each phase ensuring nothing is overlooked, from initial document review to final AUSTRAC enrolment submission.
Risk Mitigation
Identifies common implementation risks and bottlenecks, helping you anticipate challenges and plan contingencies before they become critical issues.
Who Needs This
Reporting entities starting late in the compliance timeline who need to fast-track their implementation without missing critical steps.
Firms coordinating between management, compliance officers, IT teams, external lawyers and potentially outsourced AML providers.
Organisations where full system integration is unlikely by the deadline, requiring a pragmatic manual-process implementation approach.
Newly regulated entities with no prior AML/CTF compliance experience who need structured information on implementation sequencing.
What's Included
- Complete implementation timeline with phase-by-phase breakdown
- Critical milestone dates aligned to 1 July 2026 (enrolment opens 31 March 2026)
- Task checklists for each implementation phase
- Resource allocation details (time, budget, personnel)
- Risk mitigation strategies for common implementation bottlenecks
- Coordination framework for working with external advisors
Important Notes
The Implementation Plan is a generic timeline requiring customisation to your specific circumstances. Your solicitor should review and adjust timeframes based on your organisation's complexity and resource availability.
This plan does not guarantee compliance outcomes. You remain responsible for meeting all regulatory obligations and relevant deadlines.