How IdentityCheck maps to your Tranche 2 AML obligations
Overview. IdentityCheck helps you meet the customer-facing parts of Tranche 2: initial customer due diligence, the customer risk assessment, enhanced due diligence, ongoing monitoring, and the record keeping behind them. It does not enrol you with AUSTRAC, write your AML/CTF program, appoint your compliance officer, or lodge your reports. Those remain your firm's responsibility.
This article is general information, not legal advice. IdentityCheck helps you meet several obligations; it does not by itself make your firm compliant. Confirm your specific duties against the live AUSTRAC guidance.
Download the Tranche 2 Quick Start Guide (PDF)
Does IdentityCheck make me compliant?
No, and it is important to be clear about this. Compliance is a whole-of-firm state that includes enrolling with AUSTRAC, having a documented AML/CTF program, appointing and notifying a compliance officer, doing your customer due diligence, monitoring, reporting where required, and keeping records. IdentityCheck is built to help you with several of those parts, especially the customer-facing ones, but it cannot make your firm compliant by itself.
The honest way to think about it: IdentityCheck does the identity, risk and record-keeping work well, and gives you defensible evidence that you did it. The obligations that are about your firm's own governance and its reporting to the regulator stay with you. Treat the product as a tool that helps you meet obligations, not as a substitute for your program.
Which obligations does it cover?
Here is the obligation-by-obligation view, using the customer-due-diligence parts of Tranche 2.
| Obligation | How IdentityCheck helps |
|---|---|
| Initial CDD (identity verification) | Verify your clients' identity to a documentary and biometric standard, and collect client and associated-party details through custom intake forms. |
| Customer risk assessment | Rate each customer's AML risk with a consistent, auditable methodology that produces a high, medium or low rating. |
| Enhanced CDD | Automatically escalate high-risk customers to Enhanced Due Diligence with a structured workflow. |
| Ongoing CDD and monitoring | Keep customers under ongoing sanctions, PEP and adverse-media screening and scheduled review. |
| Record keeping | Maintain a defensible, time-stamped record of the due diligence you performed. |
Each of these maps to a real obligation a Tranche 2 reporting entity now carries. Verifying identity before you provide a designated service is initial CDD. Rating and re-rating risk is the customer-level part of your risk assessment. Escalation covers enhanced due diligence. Ongoing screening and periodic reviews cover ongoing monitoring. The audit trail supports record keeping.
Does it lodge my SMRs?
No. IdentityCheck does not lodge suspicious matter reports (SMRs) or threshold transaction reports (TTRs), and it does not decide for you whether a report is required. Reporting to AUSTRAC is a firm responsibility and a judgement call that sits with your people and your compliance officer.
What IdentityCheck does give you is the evidence base: the verification results, the risk rating and its reasoning, the screening hits, and a time-stamped history of what was done and by whom. That record helps you make and support a reporting decision, but the decision and the lodgement remain yours.
What IdentityCheck does not do
To set expectations plainly, IdentityCheck does not:
- Enrol your firm with AUSTRAC.
- Write your AML/CTF program document.
- Appoint or notify your compliance officer.
- Lodge suspicious matter reports or threshold transaction reports.
These are your firm's own obligations. IdentityCheck helps you meet the customer due diligence, risk assessment, monitoring and record-keeping parts, and gives you the evidence trail to show you did the work.
Where to start
If you want the regulatory background first, read Tranche 2 AML reforms explained and Designated services under Tranche 2: am I in scope?. If you are ready to see the product in action, read What is IdentityCheck? and then run your first verification.
Frequently asked
Does IdentityCheck make me compliant? No. IdentityCheck helps you meet specific customer-facing obligations: verifying clients, assessing and monitoring their AML risk, and keeping records. It does not write your AML/CTF program, appoint your compliance officer, enrol you with AUSTRAC, or lodge your reports. Those remain your firm's responsibility.
Which obligations does it cover? It helps with initial customer due diligence (identity verification and information collection), the customer-level risk assessment, enhanced due diligence for high-risk customers, ongoing monitoring, and the record keeping and audit trail behind all of it. Enrolment, your program document and reporting sit outside the product.
Does it lodge my SMRs? No. IdentityCheck does not lodge suspicious matter reports (SMRs) or threshold transaction reports (TTRs). Reporting to AUSTRAC remains your firm's responsibility. The product gives you the due-diligence evidence and audit trail, but you decide on and submit any reports yourself.