Do I still need a solicitor for AML/CTF Tranche 2 compliance?

Yes. HeadStart Docs products are digital publications that give you a substantial head start, but they must be reviewed and tailored by a qualified solicitor to your specific business circumstances before implementation.

How is HeadStart Docs different from the free AUSTRAC Starter Kits?

AUSTRAC Starter Kits are generic starting points that require significant customisation. HeadStart products are sector-specific, pre-populated with industry-relevant risk factors and scenarios, and include 12 months of AML Portal access for ongoing compliance including screening, record keeping and reporting tools.

What if the AML/CTF rules change after I purchase?

Your digital products are yours to keep. If significant regulatory changes occur, updated versions will be available to active portal subscribers. The AML Portal itself is continuously updated to reflect current AUSTRAC requirements and sanctions lists.

What happens after my 12-month AML portal access expires?

Your documentation is yours forever. To continue using the AML Portal (screening tools, compliance calendar, record keeping), you pay $35 per customer CDD. Cancel anytime — no subscription required.

Is HeadStart Docs a law firm?

No. HeadStart Docs is a digital publisher and platform provider. We sell digital compliance products and portal access. We do not provide legal advice. Referrals for legal advice can be made to our related law firm, HeadStart Counsel.

When does AML/CTF Tranche 2 commence in Australia?

Tranche 2 AML/CTF obligations commence on 1 July 2026. All reporting entities in designated sectors including lawyers, accountants, real estate agents, conveyancers, and trust and company service providers must have their AML/CTF programs in place by this date.

When do lawyers become reporting entities under Tranche 2?

Lawyers become reporting entities when providing designated services such as creating trusts, assisting with M&A, organising debt financing, or managing client money for property and business transactions.

Do I need to file Suspicious Matter Reports as a lawyer?

Yes, lawyers must lodge SMRs with AUSTRAC when they form suspicions about money laundering or terrorism financing, even while maintaining Legal Professional Privilege for other communications.

What AML/CTF obligations apply to law firm trust accounts?

Law firms must implement AML/CTF controls for trust accounts including transaction monitoring, verification of fund sources and reporting of suspicious activities and threshold transactions.

Is conveyancing covered in the Legal Professionals pack?

Yes, conveyancing is included for QLD and ACT practices where lawyers perform conveyancing. Other states should use the dedicated Conveyancers pack.

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Legal Sector

AML/CTF Program

Name: HeadStart Docs
Brand: HeadStart Docs
Price: 679 AUD

Legal Sector Edition

Law practices with trust accounts or Table 6 designated services face some of the most complex Tranche 2 obligations. This pack includes sector-specific policies, a risk assessment and a configuration schedule. Complete the schedule manually or with our Plug & Play Technology and your portal configures to match. Your lawyer reviews and signs off. You could be set up within a day.

12 sector-specific compliance documentsPack-exclusive portal features unlockedConfiguration schedule drives your portalInstant download

Tranche 2 Compliance

Learn About AML for Legal Practices

* Includes specific modules for QLD and ACT conveyancing. For Conveyancing-only practices in NSW, VIC, SA, WA, TAS and NT, see Conveyancing Sector Program

$249

+GST · One-time · Instant access

Consultant-prepared AML programs typically cost $8,000 or more. Your professional starting point is $249 — or sign up and bring your own program.

Everything below is sector-specific and pre-populated for your practice.

Complete AML/CTF program documentation (12 documents, pre-populated for your sector)
Customisable services gateways and decision trees to implement any guardrails and for staff to check what is and is not a designated service
Shared CDD with e-signature: send verification requests directly to clients
Automated annual reporting: AUSTRAC reporting workflows built in
Smart Extract: AI-assisted form filling across your compliance documents
20 portal seats included
CDD at $35/customer, pay-as-you-go

The portal isn't separate from your program. It's where your program lives and operates. Your configuration schedule drives how the portal works: your CDD workflows, your screening thresholds, your compliance calendar, your reporting obligations - all pre-set to match your actual business.

Secure checkout · Instant digital delivery

Risk Intelligence for Legal Practices

Every sector faces different money laundering risks. These are the scenarios AUSTRAC will expect your program to address. They're already mapped into your pack.

Covered in Pack

Cuckoo Smurfing

Wire transfer manipulation

Criminals exploit trust accounts by structuring payments through multiple client matters to obscure the origin of illicit funds. This program includes specific controls for detecting layered trust account transactions.

Covered in Pack

DPRK Identity Fraud

Sanctions evasion

Sanctioned entities using sophisticated identity fraud to engage Australian law firms for legitimate-appearing transactions.

Covered in Pack

Testamentary Trust Abuse

Estate planning exploitation

Complex trust structures used to layer proceeds of crime through legitimate estate planning arrangements.

Covered in Pack

Shell Company Formations

Corporate veil exploitation

Requests to establish corporate structures designed to obscure beneficial ownership and facilitate money laundering.

Covered in Pack

Cash-Intensive Transactions

Physical currency risks

Large cash deposits into trust accounts for property settlements or litigation funding without clear source.

Covered in Pack

PEP Exposure

Political figure involvement

Politically exposed persons using law firms to acquire property or establish trusts to conceal wealth.

How it works

One configuration schedule drives your entire AML program and portal setup.

Download your pack

Pre-drafted policies, risk assessment and configuration schedule, all sector-specific.

Complete the configuration schedule

Your business details, designated services, risk thresholds and client onboarding process. Fill it in manually or use our Plug & Play Technology to complete it in minutes. Learn more about Plug & Play →

Your portal auto-configures

Your lawyer reviews the completed pack and configuration schedule before you go live. Your CDD workflows, screening thresholds, compliance calendar and reporting obligations are all pre-set to match your actual business. You could be set up within a day.

General information only. Not legal advice. Always take advice specific to your circumstances.

What's Included

Every free account includes sector-specific compliance documentation and full AML Portal access. Download, review with your lawyer and have your program ready before 1 July 2026.

Compliance Documents

Risk Assessment

ML/TF Risk Assessment and Customer Risk Assessment Matrix tailored to your sector.

AML/CTF Program

Your core AML/CTF program document with policies, procedures and controls tailored to your designated services.

CDD Procedures

Customer due diligence procedures, Client Information Sheet and Decision Trees.

Governance

Board Minutes, AML Officer Appointment and Employee Due Diligence documents.

Training and Compliance

Staff Training Register and Compliance Calendar for ongoing obligations.

Implementation

Implementation Plan, Enrolment Guide and Briefing Note to get started.

AML Portal Access

Sanctions and PEP Screening

Sanctions screening, PEP checks and adverse media monitoring in one place.

Compliance Calendar

Track deadlines and recurring compliance tasks with automated reminders.

CDD Record Keeping

Centralised record keeping with immutable audit log for every action.

Plug & Play Technology

Complete one configuration schedule and your portal configures automatically. Takes minutes, not days. Learn more →

Transaction Reporting

Built-in tools for threshold and suspicious matter reporting workflows.

Training Records

Personnel training record-keeping with completion tracking and reminders.

20 seats included with Standard edition. 100 seats with Group edition. CDD is $35 inc GST per customer.

Who May Be Captured

Tranche 2 is broader than most people expect. If any of the following describes your practice, you're a reporting entity and you need an AML program before 1 July 2026.

Sole practitioners

Independent lawyers providing designated services

Independent practices

Small to medium law practices

Law firm partnerships

Traditional partnership structures

Multi-disciplinary practices

Firms offering legal and other professional services

Conveyancers

Real estate transactions are a key designated service

Outsourced legal service providers

In some cases

Whether you are captured depends on the designated services you provide. If unsure whether you're covered, please seek legal advice. Even if you are not covered, you may consider implementing guardrails to ensure you don't accidentally cross lines.

Built Upon National and International Standards

NRA: Money Laundering(2024)•NRA: Terrorism Financing(2024)•NRA: Proliferation Financing(2022)•LCA: AML/CTF Guidance(2024)•FATF NRA Guidance(2025)

Need more context before you start?

Not sure if your practice is captured? Read our free Legal Sector guide first. It covers exactly which services trigger your obligations and what AUSTRAC will expect to see.

What happens after I sign up?

Three simple steps from sign-up to compliance.

Download immediately

Your complete sector-specific program documents are available in your portal immediately. No waiting, no onboarding.

Complete your configuration schedule

Fill it in manually or use our Plug & Play Technology to complete it in minutes. This single document sets up your portal and forms part of your compliance documentation. Your lawyer reviews the completed schedule and program before you go live. See how it works →

Go live before 1 July 2026

Use the AML Portal to run your compliance program digitally, or take the documents to your own systems. Either way, you get a complete starting point ready for your lawyer to review. Your obligations are ongoing and the portal is built to help you manage them.