Can a Tranche 1 business be mixed with Tranche 2 entities under one reporting group?
Yes, AUSTRAC's Reporting Group framework allows mixed Tranche 1 and Tranche 2 entities under one lead entity, one AML/CTF Program and one Risk Assessment.
Yes, in principle - AUSTRAC's Reporting Group framework (which replaced the old DBG structure on 31 March 2026) allows entities with different obligation profiles to be brought under one lead entity, one AML/CTF Program and one Risk Assessment. easyAML has set up mixed Tranche 1 / Tranche 2 reporting groups before, though the configuration needs to be planned carefully.
Practical considerations:
- Lead entity choice. Usually the entity with the broader obligation set (Tranche 1) is the lead, so the group inherits the more demanding controls.
- Designated services in the Program. The single AML/CTF Program must cover both regimes' designated services explicitly - Tranche 1 services have been regulated since 2006 and have more different obligations; Tranche 2 services have new sector-specific guidance.
- Compliance Officer coverage. One CO can oversee the group, but they need to understand both regimes' risk profiles. Most groups end up with the CO plus at least one 2IC with sector-specific knowledge.
- Initial scoping call. Because the configurations vary, easyAML runs a short fact-checking call before sign-up to map your entities to the right structure and confirm the platform can support them today.
See AUSTRAC's Summary of changes for current reporting entities for the Reporting Group framework.