AUSTRAC Free Starter Kits vs Paid AML Programs
In January 2026, AUSTRAC released official free starter program kits for Tranche 2 reporting entities. This comprehensive guide compares what's included, what's missing, and when each option is appropriate for your business.
Disclaimer: This article is general information only. It is not legal, financial or compliance advice. HeadStart Docs™ provides free compliance documents, not legal services. We do not guarantee the accuracy of information provided. Always seek advice specific to your circumstances from a qualified professional.
What Are the AUSTRAC Starter Kits?
AUSTRAC (Australian Transaction Reports and Analysis Centre) released free starter program kits in January 2026 to help businesses prepare for Tranche 2 AML/CTF obligations. These kits provide foundational documents that reporting entities can customise for their specific circumstances.
Each kit contains approximately 35-50 static Word documents and PDF guidance materials, covering policy, procedures, customer forms, personnel forms and effectiveness testing.
Sectors Covered by AUSTRAC Kits
AUSTRAC Kit Available
- Legal Professionals (51 documents)
- Accounting Professionals (39 documents)
- Real Estate Agents (40 documents)
- Conveyancers (49 documents)
- Precious Product Dealers (36 documents)*
*Kit limited to physical currency transactions of $10,000+
No AUSTRAC Kit Available
- Trust & Company Service Providers (TCSPs)
- Property Developers
- Insolvency Practitioners
- Business Brokers
These sectors require alternative documentation sources
Who AUSTRAC Designed These For
According to AUSTRAC's own guidance materials, the starter kits are intended for specific types of businesses:
"These starter kit resources are intended as a starting point for smaller reporting entities with 15 or less personnel."
- AUSTRAC Guidance Materials, January 2026
Key Criteria for AUSTRAC Kit Suitability
-
15 or fewer personnel
Sole practitioners and small practices with limited staff
-
Lower-risk customer profiles
Predominantly domestic, low-complexity customer base
-
New to AML/CTF obligations
Businesses entering the regime for the first time under Tranche 2
-
Capacity for manual document management
Able to customise, maintain and update Word documents manually
What's Inside Each Kit
Each AUSTRAC starter kit contains documents across several categories. Here's a breakdown of what's included:
| Category | Documents | Purpose |
|---|---|---|
| Core Program | 3 | Policy, Process, ML/TF Risk Assessment |
| Customer Forms | 12-17 | CDD by entity type, onboarding, periodic reviews, escalations |
| Personnel Forms | 5 | Staff DD, AML/CTF roles, compliance officer designation |
| Effectiveness Testing | 10-12 | SMR, TTR, CBM, onboarding, EDD effectiveness checks |
| Guidance Materials | 4-6 | Getting started guide, examples, document library |
Feature Comparison: Free vs Paid
This table compares key features between AUSTRAC's free starter kits and typical paid AML/CTF program solutions:
| Feature | AUSTRAC Free Kit | Paid Programs |
|---|---|---|
| Format | Static Word/PDF | Digital portal |
| Sanctions Screening | Not included | Included |
| Training Records | Not included | Included |
| Compliance Calendar | Not included | Automated reminders |
| Customer Risk Rating | Manual spreadsheet | Automated scoring |
| Audit Trail | Manual records | Automatic logging |
| Regulatory Updates | One-time download | Ongoing updates |
| Implementation Support | None | Available |
What the Kits Don't Include
While the starter kits provide a solid foundation, they don't include several components that many businesses need for comprehensive compliance:
Sanctions Screening
No PEP or sanctions list checking capability. You need separate solutions for DFAT, UN and other sanctions lists.
Training Management
No training modules, completion tracking, or certificate generation for staff AML/CTF training.
Digital Workflows
Static Word documents require manual processing. No automated form submissions or approvals.
Compliance Calendar
No automated reminders for periodic reviews, annual reports, or effectiveness testing deadlines.
Sector-Specific Considerations
Precious Product Dealers (Jewellers)
The AUSTRAC kit for jewellers specifically covers transactions in physical currency of $10,000 or more. If your business also:
- Deals in bullion (gold, silver, platinum, palladium)
- Provides loans secured on precious items
- Accepts virtual assets or cryptocurrency
- Provides custodial or storage services for precious items
You may need additional documentation beyond what the free kit provides.
Legal Professionals
The Legal kit includes an LPP (Legal Professional Privilege) form. However, the interaction between LPP and suspicious matter reporting obligations requires careful consideration. The kit provides a starting point but specific advice is needed for your practice.
Real Estate Agents
The Real Estate kit is designed for standard agency activities. If your business also involves property development activities, the generic kit may not fully address your obligations as a property developer.
Decision Framework
Use this framework to help determine which option may be more appropriate for your business:
AUSTRAC Free Kit May Be Sufficient If:
- Sole practitioner or very small practice (under 15 personnel)
- Predominantly lower-risk, domestic customer base
- Comfortable maintaining Word documents manually
- No requirement for sanctions screening
- Your sector has an AUSTRAC kit available
Consider Paid Programs If:
- More than 15 personnel requiring training records
- Higher-risk customers or international transactions
- Prefer digital workflows over manual documents
- Need sanctions screening or PEP checking
- Your sector doesn't have an AUSTRAC kit (TCSPs, Property Developers, etc.)
- Want ongoing regulatory updates and support
Key Takeaway
AUSTRAC's free starter kits are a valuable resource for smaller, lower-risk reporting entities entering the AML/CTF regime. They provide a legitimate starting point that can be customised to your circumstances. However, they require professional review, customisation and ongoing maintenance.
For larger practices, higher-risk profiles, sectors without AUSTRAC coverage, or businesses wanting digital workflows and ongoing support, a more comprehensive paid solution may be more appropriate.
HeadStart program documents include Plug & Play Technology that configures your AML Portal in minutes rather than weeks. You fill in your details, have your solicitor review the completed program, and go live. You can change your configuration at any time.
Download the Free AUSTRAC Starter Kits
Access all five AUSTRAC starter kits in one convenient download, organised by sector.