With Tranche 2 enforcement looming in July 2026, the clock is ticking. For the first time, Australian law firms will be pulled into the scope of anti-money laundering and counter-terrorism financing (AML/CTF) regulations.
But many law firms aren’t ready, particularly when it comes to identity verification.
Manual checks, photocopied IDs, and outdated onboarding processes may have been sufficient in the past, but under Tranche 2, they won’t be enough.
Worse still, these legacy methods can make your firm a target for bad actors. Criminals looking to launder money or conceal illicit activity don’t try their luck with firms that have strong AML controls — they actively seek out those with weaker defences.
The way criminals commit fraud has changed. Gone are the days of obvious fake IDs and doctored scans. Today’s fraudsters employ increasingly sophisticated tools, including AI-generated identity documents and realistic deepfakes, to evade outdated verification systems.
Some of the increasingly common techniques include:
In this rapidly evolving environment, manual or paper-based checks, such as verifying a driver’s licence in person or accepting scanned documents via email, are no longer fit for purpose. They’re not only easier to manipulate by bad actors, but as regulatory scrutiny increases, they also create audit and scalability challenges for law firms.
To effectively counter digital forgeries, law firms need identity verification systems that bring together advanced tools, including document verification, liveness detection, facial biometrics and real-time data validation.
To stay ahead of both criminals and regulators, law firms must modernise their identity verification practices. Advanced identity verification (IDV) combines AI, biometrics, and real-time data to deliver a much stronger and more compliant onboarding process. Here's how:
Advanced identity verification platforms use AI to analyse IDs in real time, spotting subtle signs of forgery invisible to the human eye. Machine learning algorithms compare documents against global databases of document templates, identifying inconsistencies in layout, fonts, holograms and image placement.
For example, GBG’s document authentication runs over 50 forensic checks per ID, including biometric chip analysis. It can instantly detect fake IDs, font tampering, deepfakes, face swaps and digital manipulation, drawing from the world’s most extensive library of government-issued ID templates.
Facial recognition and liveness detection ensure the person presenting the ID is not only real but also the rightful owner of the document. This is especially important for remote onboarding, where the risk of impersonation is higher.
For instance, GBG’s biometric verification includes:
Cross-checking personal information against independent sources adds another critical layer of fraud detection. Inconsistencies, such as mismatches in names, addresses or birthdates, can quickly flag suspicious activity.
For this to be effective, access to an extensive range of data sources is critical. GBG provides access to Australia’s most comprehensive identity data, including Experian credit header, tenancy, super & payroll, Australian Death Check, and many more authoritative sources.
Verification isn’t a one-and-done task. Ongoing monitoring tools track changes in a client’s risk profile over time, including new sanctions listings, adverse media, or unusual transaction patterns.
GBG’s ongoing screening tools automate this process with:
This continuous monitoring supports law firms in meeting ongoing customer due diligence (OCDD) obligations under Tranche 2.
Advanced IDV does more than tick regulatory boxes. It strengthens your firm’s overall risk posture and reputation. By preventing fraud, ensuring compliance, and fostering client trust, it can help your firm avoid penalties, protect its reputation, and attract and retain clients, giving you a competitive edge in the market.
The strength of your compliance program depends on the strength of your technology partner. That’s where GBG stands apart.
With over 30 years of experience and nearly 40 million electronic identity verifications annually, GBG is trusted by leading businesses across Australia and New Zealand.
Tranche 2 enforcement is scheduled to begin in July 2026. Early adoption of advanced identity verification isn’t just a matter of ticking boxes. It’s a strategic investment in your firm’s future resilience.
Firms that act now will be better positioned to navigate the shift to new compliance, keeping regulators satisfied and deterring criminal actors, while maintaining the trust of their clients in an increasingly high-risk landscape.
Partnering with a trusted provider like GBG can ensure you meet all regulatory requirements while minimising disruption to your client experience. Contact our team of experts today to learn more about how we can help.