Do I still need a solicitor for AML/CTF Tranche 2 compliance?

Yes. HeadStart Docs products are digital publications that give you a substantial head start, but they must be reviewed and tailored by a qualified solicitor to your specific business circumstances before implementation.

How is HeadStart Docs different from the free AUSTRAC Starter Kits?

AUSTRAC Starter Kits are generic starting points that require significant customisation. HeadStart products are sector-specific, pre-populated with industry-relevant risk factors and scenarios, and include 12 months of AML Portal access for ongoing compliance including screening, record keeping and reporting tools.

What if the AML/CTF rules change after I purchase?

Your digital products are yours to keep. If significant regulatory changes occur, updated versions will be available to active portal subscribers. The AML Portal itself is continuously updated to reflect current AUSTRAC requirements and sanctions lists.

What happens after my 12-month AML portal access expires?

Your documentation is yours forever. To continue using the AML Portal (screening tools, compliance calendar, record keeping), you pay $35 per customer CDD. Cancel anytime — no subscription required.

Is HeadStart Docs a law firm?

No. HeadStart Docs is a digital publisher and platform provider. We sell digital compliance products and portal access. We do not provide legal advice. Referrals for legal advice can be made to our related law firm, HeadStart Counsel.

When does AML/CTF Tranche 2 commence in Australia?

Tranche 2 AML/CTF obligations commence on 1 July 2026. All reporting entities in designated sectors including lawyers, accountants, real estate agents, conveyancers, and trust and company service providers must have their AML/CTF programs in place by this date.

What AML/CTF documentation do in-house counsel need?

In-House Counsel need an AML/CTF program including: Employer's Designated Services, External Service Provision, Internal Transaction Review. Our digital products provide a headstart on compliance documentation.

When does Tranche 2 commence for in-house counsel?

Tranche 2 AML/CTF obligations for law practice sectors commence from 1 July 2026. AUSTRAC enrolment opens from 31 March 2026. Businesses should begin preparing their AML/CTF programs now.

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In-House Counsel

Name: HeadStart Docs
Brand: HeadStart Docs
Price: 679 AUD

AML/CTF compliance guidance for Australian in-house counsel working within corporate legal departments. Covers when internal legal services may trigger designated service obligations.

New to Tranche 2? Read our comprehensive guide

Who is captured under Tranche 2?

May be captured

In-house counsel may be captured under Tranche 2 depending on the specific services they provide and whether their employer provides designated services or they provide external legal services as part of their role. HeadStart Docs™ provides a headstart on AML compliance, whether or not you are in scope. We recommend seeking legal advice specific to your circumstances.

Available Now: Law Practice Edition

Free program documents

A headstart on AML compliance. Program documents tailored to in-house counsel operations, from $249 one-time (or bring your own program). Your lawyer reviews and signs off before you go live.

A HeadStart on Compliance

Digital products to help you build your AML/CTF program, whether or not you are in scope

Ready-to-Customise Resources

Documentation tailored to your sector, ready to customise with your lawyer

Team Training

Staff training materials for your team and compliance officers

Key AML/CTF Areas for In-House Counsel

Our documentation covers all critical AML/CTF compliance areas specific to your profession. Your lawyer reviews and tailors these to your business before you go live. We include a structured brief so the review is efficient.

Employer's Designated Services
Understanding when employer's activities trigger obligations.
External Service Provision
Compliance when providing services to external parties.
Internal Transaction Review
AML/CTF awareness for internal corporate transactions.
Board Reporting Requirements
Escalation and reporting to corporate governance.
Third-Party Due Diligence
Reviewing AML/CTF compliance of business partners.
Suspicious Matter Procedures
Internal escalation and reporting frameworks.

What's Included in Your Law Practice Edition

Digital products tailored to in-house counsel operations, ready to customise with your lawyer.

• AML/CTF program framework for in-house counsel
• Risk assessment worksheet (ML/TF/PF risks)
• Employer obligation assessment
• External service procedures
• Internal transaction guidelines
• Board reporting templates
• Third-party due diligence protocols
• Suspicious matter procedures
• Recordkeeping schedules
• Board reporting templates

Related Sectors:

Free Tools

Implementation TimelineKey dates and milestones for Tranche 2 compliance Readiness TestAssess your compliance readiness in 2 minutes Sanctions ScreeningSearch Australian sanctions lists and country risk

Related Resources

Related Law Practice Professions

Family Lawyers Estate Lawyers Commercial Lawyers Litigators

Disclaimer: This information is general in nature and does not constitute legal advice. HeadStart Docs™ provides digital products only, not legal services. Always seek advice specific to your circumstances from a qualified legal professional before implementing any AML/CTF program. We do not guarantee the accuracy of this information.