Mello Consulting Group helps Australian SMEs meet their AML/CTF Tranche 2 obligations — backed by fifteen years in HR systems.
Start the conversationReal estate professionals. Accountants and tax agents. Lawyers and conveyancers. Trust and company service providers. Dealers in precious metals and stones.
If your business is one of them, you are about to become a reporting entity under the AML/CTF Act. You will need an enrolled business, a written program, verified customers, and staff who know what to do when something looks wrong.
Most SMEs don't have a compliance team. They have a principal, a bookkeeper, and a client list. Mello is built for that reality.
AML/CTF readiness leads the practice today — the commencement date is near and the work is concrete. Underneath sits fifteen years of HR systems experience for the organisations that need strategic partners, not just vendors.
Training built for SMEs in real estate, accounting, legal, and related gatekeeper professions. Program design, AUSTRAC enrolment support, customer due diligence frameworks, and staff assessment. Reviewed by specialist AML/CTF legal advisors before release.
End-to-end management of SAP SuccessFactors — updates, monitoring, troubleshooting, and optimisation. We flag issues before they reach your HR team.
Custom dashboards that show leadership where attrition risk is building, where engagement is slipping, and what is driving it.
When the standard configuration doesn't match how your organisation operates. We build around your actual processes — approvals, structures, workflows — not the other way around.
Technology strategy and roadmap advisory for HR leaders. We don't have a preferred vendor — we start with what your organisation is trying to do, then work backward to the technology.
Mello Consulting Group is a personal practice — run by me, Angelo Jr Armas, not a committee.
Fifteen years in HR systems. Eight of those in professional learning and training design.
The current focus is one product: an AML/CTF Tranche 2 training program for SMEs without a compliance officer on staff. It is being independently reviewed by specialist legal advisors before release. Credibility matters more than speed.
Every deliverable answers a specific question your business is actually asking.
Fewer people, leaner budgets, direct decisions — that is who we build for. Our work is scaled for the reality of smaller businesses, not adapted from enterprise frameworks.
If a problem is outside what we do well, we'll tell you — and where possible, point you toward someone who does.
Compliance content ages. We keep it reviewed, dated, and accurate — with a visible record of who last reviewed it and when.
It's about what you do, not what you're called. AUSTRAC's position is that you're a reporting entity because you provide one or more "designated services" — not because of your industry label. For accountants that includes managing client money, forming companies or trusts, or acting as a nominee director. For real estate it's any service connected to buying, selling, or transferring property. If you provide a designated service with a connection to Australia, you're in scope from 1 July 2026.
No — not in the way many businesses hope. From 1 July 2026, your AML/CTF program, staff training, enrolment, and customer due diligence obligations all apply in full. There's no general grace period for getting compliant.
The one piece of transitional relief is for your initial independent evaluation. As a newly regulated Tranche 2 entity, you can set an extended deadline for that first evaluation, determined by your AUSTRAC account number — at least three years out. Everything else is expected from day one.
Enrolment opened on 31 March 2026 and closes on 29 July 2026 for newly regulated Tranche 2 businesses. You enrol through AUSTRAC Online. You'll need your ABN, your business structure details, and the details of your nominated AML/CTF compliance officer. Enrolment is administrative, but it's the gateway — your other obligations can't be met until you're on the register.
No — you can hold all three. AUSTRAC's framework sets out a governing body, a senior manager, and a compliance officer, but for sole traders and micro businesses one person can fill all of them. If that person is you, you need to understand what each role requires. You can also outsource the compliance officer role, but you remain responsible for making sure whoever you appoint meets the requirements.
Customer due diligence means identifying and verifying who your customer is before you provide a designated service — not after. It includes establishing their identity, identifying anyone acting on their behalf or any beneficial owner, checking whether they're a politically exposed person or subject to sanctions, and understanding the purpose of the relationship. For higher-risk situations you do more; for lower-risk, less. The key rule: initial due diligence comes before the service, not once the deal is underway.
Civil penalties run up to $33 million per contravention for a body corporate, and they compound — each breach is counted separately. There are criminal penalties including imprisonment for individuals. But the financial penalty is often not the worst of it: AUSTRAC publishes its enforcement actions, and for a professional firm a finding can trigger separate consequences with your professional body on top of the AUSTRAC outcome.
Training is one piece of a complete AML/CTF program — it gets your people ready to follow the program you put in place. AUSTRAC publishes free Program Starter Kits that give you the template to build your written program. The sensible approach is to use both: build your written program from the AUSTRAC Starter Kit, and use training to make sure your team understands what it requires and can actually carry it out.
One conversation is usually enough to know where you stand.