Tranche 2, plainly · Episode 3
Two myths sink more Tranche 2 businesses than any other. One: this is about my profession. Two: we're too small to count. Both are wrong — and the Act is clear on why.
Myth one — 'it's about my profession'
The regime doesn't regulate professions. It regulates services. You are not covered for being a lawyer or an agent — you are covered for providing a designated service the Act names. Do the service, and the duty attaches. Don't, and it doesn't.
A specific activity the Act lists in section 6. The duties attach to the service you provide — not to your job title, and not to everything your business does.
Myth two — 'we're too small'
And there is no small-business exemption. The regime scales — a tiny firm does less than a bank — but scaling down is not opting out. If you provide the service, size does not excuse you. It only sizes the response.
(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.
So hold both truths. You are covered for what you do, not what you are called. And you are never too small — only sized differently. Get those two right, and the folklore stops scaring you.
Function, not profession. Scaled, not exempt. Two myths, gone — and a much clearer view of exactly where you stand.