Signing up is easy. The commitment is everything that comes after.

(Same goes for taking on the role of AML Compliance Officer)

Every January, the good old New Year's Resolution leads to gyms filling up with people who sign up with the best intentions. New shoes, fresh activewear, maybe even a personal training session or two. It feels productive. Like the hard part is done.

But reality eventually shows up. The soreness. The time commitment and routine. The fact that results only come if you keep turning up, week after week, even when motivation disappears.

Enter Tranche 2 AML.

Across Australia, real estate agents, law firms and accounting practices are busy gearing up for AML/CTF compliance. There are project plans, onboarding checklists, risk assessments being drafted and somewhere in the middle of it all, someone is appointed as the AML Compliance Officer (AMLCO).

And that’s where the misunderstanding often begins.

Too many businesses are quietly thinking “Once we’ve set this up, the AMLCO work will mostly be done, right?”

Wrong.

Appointing an AMLCO is like taking out a gym membership. Once you’ve made the commitment, you’re in it for the long haul.

Appointing someone to the AMLCO role is not a one off setup task. Yes, the early days of AML compliance feel busy:

• Risk assessments

• AML/CTF Programs

• Procedures, technology, training and enrolment with AUSTRAC

But Tranche 2 laws don’t say “Congratulations on setting this up, see you later.” They say “Welcome. Now maintain it. Forever.”

The AMLCO role exists because AML is ongoing by design. Criminal methodologies evolve, clients change, new products and services are introduced, staff turnover happens and your business does not stand still.

Which brings us to the reality check.

The Top 5 Ongoing Responsibilities of an AMLCO.

This is not the full list, but it’s enough to prove the point.

1. Keeping the AML/CTF Program alive (and not dusty) - An AML/CTF Program is not a document you frame and hang on the wall. The AMLCO must review it regularly, update it when services, client types, or risk exposure changes, make sure it actually reflects how the business operates in practice. New service? New jurisdiction? New client type? That’s a program update. This is less set and forget and more like staying consistent with training when life gets busy.

2. Ongoing customer due diligence oversight - AML obligations don’t stop once a client is onboarded. The AMLCO is responsible for ensuring ongoing due diligence is happening, higher risk clients are reviewed more frequently, red flags are escalated and addressed

3. Enhanced Due Diligence (EDD) is actually enhanced - Clients change. Ownership structures change. Behaviour changes. AMLCOs are there to spot when your long term client suddenly starts behaving… differently.

4. Monitoring transactions and behaviour over time - In Tranche 2 industries, money flows are often complex: property settlements, trust accounts, client monies, third party payments

5. The AMLCO must ensure systems and processes exist to: identify unusual or suspicious behaviour, escalate concerns internally, decide when reporting thresholds are met

This isn’t a once a year check in. It’s ongoing monitoring, like tracking progress over time rather than stepping on the scales once and calling it done.

And there's still more to be done

Training staff (again… and again… and again)

Staff turnover is inevitable. Which means AML training is never finished. The AMLCO must ensure: new staff are trained. existing staff receive refresher training, training reflects real risks the business faces, staff actually understand their obligations (not just tick a box).

Repeatedly needing to explain the importance of doing AML properly can feel like starting a new training plan, only to realise half the team never learned the basics. But that’s the job.

Being the person AUSTRAC calls

This one is non negotiable. The AMLCO is the primary contact for AUSTRAC, responsible for responding to regulator queries, accountable during audits, reviews and investigations and on the hook if things go wrong.

AUSTRAC doesn’t call the business. They call the AMLCO. Real estate agents, lawyers and accountants are experts in their fields, but AML is not traditionally one of them. Which is why many firms are discovering that the AMLCO role doesn’t fit neatly into an already full time job, that compliance doesn’t slow down once the setup phase is over and that “We’ll manage it internally” sounds easier than it actually is.

So what’s the solution?

You have two realistic options:

1. Train and permanently resource an internal AMLCO

2. Add the AMLCO role to an existing senior management position’s role if you're in a smaller organisation

The second option can be made more robust through training or seeking ongoing support from an external AML advisory firm like Agentic AML.

There’s no wrong answer, you just need to be honest about the ongoing commitment.

Final thought

AML compliance is not a one off setup exercise. And it’s definitely not something you only worry about in year one.

So if you signed up for Tranche 2 thinking it was just a quick onboarding sprint, give Agentic AML a call and we’ll help you build something sustainable.