Skip to content

Can I share my AML resources across multiple businesses? Let’s look at how Reporting Groups work

Published October 17, 2025

If you own or operate more than one business, the thought of building a separate AML/CTF program for each one might already have you researching early retirement options. The good news? AUSTRAC’s Tranche 2 reforms introduce a practical mechanism called ‘Reporting Groups’ which are designed to make compliance more manageable when you’ve got multiple entities under your umbrella.

In this article, we’ll unpack what reporting groups are, why they exist, and how they can help reduce duplication while still meeting your obligations.

What is a reporting group?

Under the new rules, reporting groups simplify and replace the old concept of “designated business groups (DBGs).” A reporting group allows two or more related businesses to share parts of their AML/CTF compliance framework, such as:

This means that rather than every business building a program from scratch, you can create a common program that applies across the group, provided it’s still tailored to the risks each entity faces.

Why did AUSTRAC introduce reporting groups?

Even before Tranche 2, AUSTRAC recognised that many businesses don’t operate as single stand-alone entities. It’s common for SMEs to have multiple businesses underneath one overarching entity. Some real-life examples include:

Without the concept of reporting groups, each of these businesses would have to duplicate effort. They would each need to conduct a separate risk assessment, write a separate program, and manage separate monitoring and reporting systems. Reporting groups make it possible to streamline compliance, reduce duplicated admin, and keep costs under control.

How reporting groups work

If you’re considering forming a reporting group, there are some key factors you need to consider:

You need a lead entity.

One business in the group must take the lead in developing and maintaining the AML/CTF program. That entity is considered to be the lead entity and is responsible for ensuring the program covers the risks of the whole group.

Each member is still responsible.

Even though you share resources, each business in the group remains legally responsible for meeting its obligations. If one member drops the ball, AUSTRAC can still take enforcement action against that entity.

The program must be risk-based.

The shared AML/CTF program must address the risks each business in the group may reasonably face. That means if one arm of the group is higher risk (say, an international property arm dealing with foreign clients), the group program must account for those risks.

You must document it.

Just like a standalone program, a reporting group AML/CTF program must be written, board-approved (if applicable), and independently reviewed on a regular cycle.

Enrollment still applies.

Each entity in the group that provides designated services must enrol/register with AUSTRAC in its own right, even if it shares the group program. As part of the enrolment process, you will be able to specify that you belong to a reporting group (and who the lead entity is). The lead entity must specify their reporting group members as part of their enrollment.

Real-world examples

These concepts can sometimes be a little wordy and abstract, so we find that sometimes it’s easiest to understand through examples:

An accounting group

Smith & Co Accounting runs three entities - one for tax, one for SMSFs, and one for bookkeeping. Rather than running three separate AML/CTF programs, they establish a reporting group. Their compliance officer sits across all entities, supported by one risk assessment and program that accounts for the risks of each service line.

A real estate network

A boutique real estate agency operates four offices, each as a separate company. They create a reporting group, allowing one set of customer due diligence procedures, one training framework to cover all of their staff, and one reporting process to cover the entire network.

A law + conveyancing combo

A firm operates a legal practice under one ABN and a conveyancing business under another. Because both will be captured under Tranche 2, they form a reporting group. This way, staff training, transaction monitoring, and record-keeping are consistent across both entities.

What are the benefits of a reporting group?

What are the ‘orange flags’ or things to consider?

Reporting groups are not a “free pass” that passes the buck from the individual entities to the lead entity.  Every member still needs to ensure that:

Another way to think of it is that reporting groups let you share the heavy lifting, but you can’t outsource accountability.  

AML compliance without the headache

If you’re a Tranche 2 SME with multiple businesses, reporting groups are a smart way to manage AML/CTF compliance without drowning in duplication. But the earlier you start planning, the smoother it will be. Setting up a shared framework, appointing a group compliance officer, and making sure your risk assessments and customer due diligence cover all entities takes time.

The businesses that prepare early will find themselves calm and confident by July 2026. Those that delay may be scrambling to retrofit a group program under pressure.

Next steps

1. Join our upcoming webinar

We run regular webinars that tell you everything you need to know about Tranche 2, including practical examples and AUSTRAC’s expectations to help you decide if a group approach is right for your business. 

2. Consider whether an enterprise solution is right for you

For high-volume businesses operating across multiple entities, easyAML offers an Enterprise plan with:

It’s everything you need to manage compliance calmly, without multiplying your workload. You can use our Pricing Calculator to work out which plan suits your unique business.

The bottom line when it comes to Reporting Groups

Yes, you can share resources across multiple businesses. That’s exactly what AUSTRAC’s reporting groups are designed for. But it only works if you set things up properly: shared risk assessments, a strong group program, clear accountability, and consistent implementation.

The key? Start planning now, not later. Then, but the time Tranche 2 rolls around, you can face it with confidence, not a compliance headache.

For more information on Trache 2 and your obligations, head to https://easyaml.com/tranche-2/key-dates/ and to ensure you keep up to date with all the latest updates from AUSTRAC, be sure to register for our Readiness List.