AML/CTF for small teams: How to build compliance Into roles without burning your team out

If you run a small team, the idea of adding another regulatory obligation can feel exhausting before you’ve even started. For many Tranche 2 businesses we speak to, their immediate reaction to AML/CTF is: “How are we supposed to do this on top of everything else?” It’s a fair question.

Real estate agencies, conveyancing practices, law firms and accounting businesses are already lean by design. People juggle client work, admin, compliance, business development and (somehow) still try to leave on time.

The good news? Tranche 2 AML/CTF compliance doesn’t require a dedicated compliance department. What it does require is smart role-splitting, clear ownership, and the right tools to support your team. Remember that in this blog, we’re talking specifically to businesses with small teams (up to around 10 staff) and what Tranche 2 looks like for them. If you’re a sole operator without a team reading this and feeling overwhelmed, please don’t panic - we have another article coming soon to support you with real practical guidance specifically for solo biz owners who don’t have that team available to divy up the load. 

If you’re looking to support your small team through the Tranche 2 changes, stick with us as we break down how you can build AML/CTF into existing, everyday roles without overload, confusion or burnout.

First, let’s reset expectations

In theory, AML/CTF compliance isn’t meant to sit on one person’s shoulders entirely. The Act and the Reforms Guidance from AUSTRAC talks about boards, and compliance teams, but often for small businesses, this isn’t the reality. With many small business owners and employees already experiencing burnout, it is important to consider how these new compliance obligations could be implemented without causing additional stress.

In small teams, burnout usually happens when:

• responsibilities are unclear
• tasks are duplicated or missed
• compliance relies on memory and manual processing instead of systems
• everything escalates to the same person (and we see bottlenecks occur)

We recommend framing your Tranche 2 obligations not with the intention to turn everyone in your team into a compliance expert, but instead, to spread responsibility sensibly, with the right level of involvement at each role.

Start with one clear owner: the Compliance Officer

Every Tranche 2 business must appoint a Compliance Officer. In small teams, this is usually:

• the owner or director
• a practice manager
• or the person who already oversees risk and processes

That’s normal, and expected. What matters is that this person understands the business end-to-end and has the authority to make decisions. They should also have visibility across clients and transactions.

The Compliance Officer’s role is oversight and accountability. They don’t need to micromanage by personally verifying every client or drafting every report, but they do need to know the process works (more on this when we cover your organisation’s risk assessment and AML program in greater detail over the coming months).

Role-splitting in practice: who does what?

Here’s how AML/CTF responsibilities can realistically be shared across small teams without overload.

1. Frontline staff: spotting and capturing, not deciding

Frontline roles, such as conveyancing assistants, paralegals or client managers, are often closest to clients. Their AML/CTF role should be awareness-based, not technical. Their responsibilities typically include:

• collecting required client information for Customer Due Diligence
• completing identity checks as part of onboarding
• following set workflows
• escalating anything unusual to the Compliance Officer

They aren’t expected to submit Suspicious Matter Reports, only to be aware of red flags and be able to follow your internal process to escalate those matters where something doesn’t smell quite right. This keeps the burden light while ensuring risks are surfaced early through the escalation process.

2. Admin and operations: consistency and record-keeping

In many small teams, admin or operations staff play a quiet but critical role in maintaining accurate records and checks. Your admin team’s AML/CTF contribution might include things such as:

• ensuring required checks are completed before work proceeds
• confirming records are saved correctly
• maintaining file completeness
• supporting reporting workflows

This mirrors what already happens in many conveyancing, legal and accounting practices where compliance steps are embedded into file progression, not bolted on at the end.

3. The Compliance Officer: judgement, escalation and oversight

The Compliance Officer is where the decision-making sits. Things like reviewing escalated matters from frontline staff, assessing risk levels and deciding whether additional information is required as well as reviewing and approving suspicious matter reporting.

Your Compliance Officer should also be overseeing training and reviews, and ensuring records are retained. 

Why small teams struggle without structure

Without clear role-splitting, we see time and time again compliance obligations (not unlike the upcoming Tranche 2 obligations) often turning into comments like “someone else will handle that”, “I’ll fix that later” or “I’ll remember that”.

That’s where stress (and error) creeps in.

Compliance becomes reactive. It’s not routine.

You and your team feel constantly on edge about missing something.

The solution? Better structure. And this is where technology becomes the enabler.

Think about how your team already works.

You don’t manage matters, settlements or clients purely from memory. You use some kind of practice management software or CRM. Of course you do, because it means that:

• tasks are assigned automatically
• steps are visible
• records are centralised
• progress is easy to track
• nothing relies on one person remembering everything

Your AML/CTF compliance works the same way.

When compliance is managed manually, tasks sit in people’s heads, oversight becomes difficult and burnout risk increases. Conversely, when it’s supported by technology:

• workflows guide each role
• escalation is built in and processes are known
• records are automatic
• teams feel supported, not stressed

We’re firm believers that technology doesn’t replace people. Instead, it protects them from overload and makes time-consuming, repetitive tasks simple and straight-forward and takes away much of the mental load that comes with compliance.

Building AML into your existing roles

For small teams, sustainable compliance usually looks like your frontline staff following guided workflows, supported by your admin staff who ensure completeness and consistency. Your Compliance Officer then reviews exceptions only, supported by a system that handles training, reminders and records.

Everyone knows their role. And no one is carrying the full weight alone.

Where easyAML fits for small teams

easyAML was built with small teams in mind. It supports role-based compliance by embedding AML steps into everyday workflows and centralising your records, evidence and audit trails.

Our intuitive system flags exceptions and supports your Compliance Officer with visibility and control.

Put simply? It reduces the manual admin that typically leads to burnout.

Ready to make AML/CTF manageable for your team?

If you’re a small team preparing for Tranche 2, now is the time to put the right foundations in place, before compliance becomes a pressure point.

Get started with easyAML and see how our structured workflows and smart automation can support your team without burning anyone out. Because compliance should fit your business, not the other way around.