Tranche 1 · Digital currency exchanges
AML compliance for digital currency exchanges
Exchange of digital currency for money (and related services) sits at the centre of AUSTRAC’s original digital currency regime. Strong KYC, ongoing monitoring and clear audit trails are non-negotiable. Trancher provides the operational layer to meet them efficiently.
Am I captured?
Exchanging digital currency for money, and related designated services, is already captured under AUSTRAC’s AML/CTF regime.
Designated services include:
- Exchanging digital currency for money, or money for digital currency
- Related onboarding and safekeeping services that form part of that exchange business
Many operators now also fall under the expanded VASP rules — check both.
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. Onboarding and ongoing monitoring are the product, not an add-on. A wallet you cannot attribute, or a customer you cannot re-identify when risk changes, is the typical failure AUSTRAC looks for.
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 exchange could be used for money laundering or terrorism financing — customers, services, delivery channels and geography — and keep that assessment current as your operations change.
AML/CTF program
Put in writing how your exchange 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
KYC, customer and wallet attribution, screening, ongoing monitoring and audit-ready records that keep pace as risk changes, with reporting support when required.
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 business — 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
Articles for digital currency exchanges
Tranche 2 Obligations: 2026 AUSTRAC Readiness Guide
What if the 1 July 2026 deadline wasn’t a threat to your firm’s productivity, but the catalyst for a more profitable advisory model? We know that…
View article →
What Happens During an AUSTRAC Audit? Guide for SMEs
An AUSTRAC audit is not a regulatory “gotcha” moment designed to catch you out. It’s a structured systems check to ensure your firm’s integrity…
View article →
Cost of AML Non-Compliance: 2026 Guide for Australian SMEs
Did you know that as of 1 July 2026, a single systemic failure in your anti-money laundering processes could trigger a maximum civil penalty of $36.4…
View article →Questions from digital currency exchanges
Am I captured?
Digital currency exchanges have been reporting entities under Tranche 1. Obligations arise when you provide designated digital currency exchange services. Enrolment and registration requirements apply.
What are the deadlines?
Tranche 1 obligations have applied for years. Enrolment and registration must be kept current. You cannot start providing the services until registration is confirmed where required. Keep your Compliance Officer nomination up to date.
What goes in the program?
Your AML/CTF program must include a risk assessment focused on digital currency exchange activity and the controls to manage those risks — customer identification and verification, transaction monitoring, PEPs/sanctions/adverse media screening, suspicious matter reporting, staff training and record-keeping.
What does CDD look like in practice?
Identify and verify customers, screen for PEPs, sanctions and adverse media, and monitor transactions on an ongoing basis. Records must demonstrate the checks performed.
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.