Tranche 1 · Superannuation
AML compliance for the superannuation sector
Superannuation fund management and related retirement services carry long-standing AUSTRAC obligations. Trancher supports consistent customer due diligence, screening, monitoring and reporting so compliance teams can keep evidence clear and current.
Am I captured?
Superannuation providers have long-standing AML/CTF obligations when they provide designated superannuation or retirement services.
Whether particular obligations apply depends on the services you provide and any relevant exemptions or modifications.
Your obligations
If you provide a designated service, you are a reporting entity. You must enrol with AUSTRAC, run a risk-based AML/CTF program, identify and monitor clients, keep records and report when the law requires it. The program already exists in most organisations. The operational gap is usually consistent KYC/KYB, screening and a file an auditor can follow — not writing the policy from a blank page.
AUSTRAC enrolment
Enrol with AUSTRAC and keep the enrolment current — including nominating a Compliance Officer. Enrolment is how AUSTRAC knows you are a reporting entity and how it contacts you.
Risk assessment
Document how your organisation could be exposed to money laundering or terrorism financing risk — customers, products and services, delivery channels, transaction activity and geography — and keep that assessment current as your operations change.
AML/CTF program
Put in writing how the organisation will meet its AML/CTF duties: who does what, how clients are identified, how higher-risk work is handled, how staff are trained and how you will check the program still works.
Customer due diligence
Identify the client (and beneficial owners where relevant), verify that identity, screen for PEPs, sanctions and adverse media, and apply extra checks when risk is higher. Repeat when circumstances change.
Reporting
Submit suspicious matter reports to AUSTRAC when you form a suspicion, and any other reports that apply to your services. Do not tip the client off that a report has been made or is being considered.
Record-keeping
Keep the program, risk assessment, identification records and transaction records for at least seven years so you can show AUSTRAC what you did and why.
How Trancher helps
Structured customer due diligence, screening, ongoing monitoring, reporting pathways and audit-ready records that support consistent AML/CTF operations across the superannuation environment.
Risk assessment and AUSTRAC-aligned program builder
Client verification (KYC/KYB) with PEPs, sanctions and adverse media screening
Ongoing monitoring and risk scoring
Reporting support (SMRs)
Staff training modules
Audit-ready records and dashboard
Three clear paths
Choose the level of support that works for your organisation — use Trancher within your existing AML/CTF operations, add expert support where needed, or have agreed activities managed for you.
1
Self-managed
Use Trancher within your existing AML/CTF program, with clear workflows and built-in guidance.
From $9.99 per week.
2
Self-managed + expert support
Use the platform day to day and bring in our compliance specialists when you need help with implementation, risk assessment, program updates, onboarding, training or operational reviews.
3
Fully managed by our experts
Ask our experienced compliance specialists to manage agreed AML compliance activities on your organisation’s behalf.
How long does it take?
Most firms move from start to operational compliance within weeks.
Days 1–7
Enrolment and risk assessment underway
Days 8–21
Workflows live and team trained
Thereafter
Fully operational and audit-ready
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View article →Questions from the superannuation sector
Am I captured?
Superannuation providers have been reporting entities under Tranche 1 where they provide designated superannuation or retirement services. Which obligations apply depends on the services provided and any relevant exemptions or modifications.
What are the deadlines?
Tranche 1 obligations have applied for years. The 2026 reforms updated obligations for existing reporting entities from 31 March 2026, subject to transitional arrangements. The focus is ongoing compliance and implementation of the updated regime rather than a new Tranche 2 commencement deadline.
What goes in the program?
Your AML/CTF program must include a written risk assessment and the policies, procedures, systems and controls used to manage money laundering and terrorism financing risk across the designated services you provide. For established superannuation organisations, the emphasis is consistent customer due diligence, screening, monitoring, reporting and an audit-ready evidence trail.
What does CDD look like in practice?
Apply customer due diligence in accordance with the designated service and applicable rules. Identify and verify customers and beneficial owners where relevant, screen for PEPs, sanctions and adverse media, and apply risk-based or enhanced due diligence when required. Ongoing monitoring should reflect changes in customer risk and activity.
How is KYC/KYB charged?
Every verification check triggers one transaction. If you are identifying individuals within an entity — for example directors, beneficial owners or authorised persons — each individual check is a separate transaction and is charged accordingly.
Disclaimer
This is a plain-English guide only and is not a determination of your firm’s status. Whether you are a reporting entity depends on the specific designated services you provide, the facts of each engagement, and the applicable items in the AML/CTF Act. If unsure, use the Am I in scope? guide or seek independent legal advice. Trancher does not provide legal advice.
Ready to simplify compliance?
Book a short overview or speak with our in-house specialists about the right path for your firm.