For agencies subject to AML/CTF Tranche 2
When someone asks what you knew, and when — what do you show them?
Collecting ID documents is the easy 80%. The part that gets tested later is whether your record of due diligence can be trusted — or whether it could have been quietly edited after the fact.
Something worth noticing
Most Tranche 2 prep focuses on what to collect. The harder question an auditor asks is can you prove nobody altered it afterward — and most shared-drive setups have no answer to that.
Named sign-off, alwaysChain-linked, tamper-evidentBuilt for AUSTRAC Tranche 2
Live record — Deal #1188, 128 Toorak Rd
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14 Aug · 09:12
Identity documents received — S. Mensah
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14 Aug · 09:38
PEP & sanctions screening completed
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14 Aug · 09:41
Sign-off recorded — reviewed by J. Okafor