Tranche 2, plainly · Episode 8
The fear every small business has about this law is the same. It'll cost a fortune, and it's built for the big end of town. Here is the honest answer — and the words in the Act that settle it.
The regime does not ask a sole practitioner to do what a major bank does. It scales. And that isn't a favour — it is written into the Act.
(2) The steps taken by a reporting entity in relation to undertaking the reporting entity's ML/TF risk assessment must be appropriate to the nature, size and complexity of the reporting entity's business.
(1) A reporting entity must undertake an assessment (an ML/TF risk assessment) that identifies and assesses the risks of money laundering, financing of terrorism and proliferation financing that the reporting entity may reasonably face in providing its designated services.
So the cost isn't a fixed number. It is proportionate. A simple business runs a simple program. A complex one does more. The law asks for appropriate — not maximal.
That is the honest cost picture. Not a fortune. Not a template built for banks. A program sized to your business — because the Act says, in those very words, that it must be.
So don't budget for someone else's regime. Build the one the Act actually asks of you — appropriate to your nature, size and complexity. Usually, that is far less than you feared.