AUSTRAC Starter Kit Assistance & Implementation

  • From 1 July 2026, newly regulated Tranche 2 professions (e.g., real estate, lawyers & conveyancers, accountants, TCSPs, jewellers) must have a fit‑for‑purpose AML/CTF framework in place. AUSTRAC has released “starter kits” to help small, low‑complexity firms get moving — but most businesses still need hands‑on help to tailor, implement, and embed those materials into day‑to‑day operations.

  • AML Advisers partners with you to map the AUSTRAC starter kit to your business model, then build the end‑to‑end program, train your people, and stand up your evidence pack so you’re regulator‑ready and efficient.

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Who this is for

  • Independent real estate and buyer’s agencies, especially small to mid‑sized teams who need a turnkey path from “kit” to “operational”.

  • Legal/conveyancing, accounting & TCSP firms preparing to enrol, appoint an AMLCO, and operationalise a risk‑based program before go‑live.

What you get (deliverables)


  • We use AUSTRAC’s reforms guidance and sector materials as the baseline, then tailor to your risk profile, delivery channels, and client mix. Includes governance, roles (incl. AMLCO), risk‑based procedures, and ongoing CDD.

  • A proportionate, documented methodology that drives your controls, with inherent/residual risk ratings and clear risk acceptance criteria.

  • Practical workflows for initial CDD (KYC), when to apply EDD, ongoing monitoring triggers, and tipping‑off safe‑guards — aligned to the reformed framework.

  • Internal red‑flag indicators, escalation templates, and a retention matrix aligned to AUSTRAC expectations (so you can demonstrate decisions and timeliness).

  • Step‑by‑step AUSTRAC Online enrolment checklist, AMLCO appointment artefacts, and your “Day‑1 Controls” plan for go‑live. Enrolment opens 31 March 2026.

  • Role‑based training (principals, sales/property teams, support staff), attendance logs, and staff attestations. AUSTRAC emphasises sustained, risk‑based implementation — training is central.

  • A tidy “evidence pack” (policies, risk assessment, CDD samples, registers, training logs, implementation plan) so you can evidence progress and effectiveness. AUSTRAC expects documented plans and progress tracking.

How it works (4–6 weeks, typical small practice)

Phase 1 — Discover & baseline (Week 1)

Scoping workshop; collect client/product/channel data; confirm whether the AUSTRAC starter kit is the right fit; map gaps.

Phase 2 — Design & tailor (Weeks 2–3)

You’re part of the process. We keep communication open and decisions shared—no black boxes or surprises.

Phase 3 — Implement & educate (Weeks 3–5)

Run staff training; stand up registers/templates; pilot CDD and records workflows; assemble your evidence pack and implementation plan. AUSTRAC wants risk‑based implementation with demonstrable progress.

Phase 4 — Assure & handover (Week 6)

When we deliver, it’s not just a finished product—it’s a solution you can trust, backed by real care and effort.

  • Why this “starter kit + implementation” model works

    Aligned to AUSTRAC’s intent: Starter kits give you a lawful, practical baseline for small/low‑complexity firms; we customise and operationalise so it fits your reality (people, systems, file flow).

  • Why this “starter kit + implementation” model works

    Regulator‑ready, risk‑based: AUSTRAC has clearly set expectations around risk‑based implementation, plans, training, and quality reporting. We build that in from day one.

  • Why this “starter kit + implementation” model works

    Date‑driven: Enrolment opens 31 March 2026; obligations commence 1 July 2026 for Tranche 2 — our plan works back from these dates.

Package options

    • Tailored AML/CTF Program & Business‑wide Risk Assessment

    • CDD/EDD/ongoing monitoring SOPs + forms & registers

    • AUSTRAC enrolment checklist + AMLCO appointment artefacts

    • 1 live staff training session + attendance logs & attestations

    • Evidence pack (+ implementation plan to 1 July 2026)

    • File readiness check (sample of 10 files) & corrective actions

    • Two additional training micro‑modules.

    • Three‑month check‑in after go‑live

    • Extended file testing (25–40 files)

    • Enhanced due diligence playbook & supplier onboarding guidance

    • Pre‑audit rehearsal and management briefing pack

  • Fixed‑fee options available on request. (We scope to your size/complexity and can work within staged budgets.)

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Frequently Asked Questions

  • AUSTRAC opens enrolment for newly regulated sectors on 31 March 2026. Tranche 2 obligations commence 1 July 2026. You must enrol within 28 days of first providing a designated service.

  • AUSTRAC created sector “starter kits” to help typical, low‑complexity firms customise and maintain an AML/CTF program. You’re not required to use the kit — but it’s a strong baseline we tailor to your business.

  • Core reforms and new Rules have been released, with AUSTRAC continuing to roll out sector guidance and transitional details. We track updates (e.g., expectations statements, sector guidance) and adjust your implementation plan if AUSTRAC refines guidance.

  • Not perfection — but genuine, risk‑based implementation: enrolment/AMLCO, a proportionate program grounded in your risk assessment, trained staff, and an implementation plan with evidence of progress.

Is the Starter Kit right for you?

You’re a strong fit if you:

1

  1. Have 15 or fewer staff (incl. admin and professional personnel)

  2. Mostly serve Australian resident individuals

  3. Don’t regularly deal with high‑risk customers/clients

  4. Don’t offer fully remote self‑service designated services

  5. Aren’t part of a large reporting group, foreign branch or subsidiary

  6. Aren’t acquiring another business/practice or transitioning clients (separate procedures apply)

Important: If you don’t meet every characteristic, you must assess and adapt your AML/CTF program. Larger or more complex operations generally require stronger or additional controls. Your program must reflect your size, nature, complexity, and ML/TF risks.

Accounting Practices — Who it’s for

2

Provide professional services (e.g. services relating to body corporates and legal arrangements)

  • Typically serve individual Australian residents

  • Exclusions: overseas property transactions; fully remote self‑service; acquisitions/transitions; large groups/foreign branches/subsidiaries

Good to know: Membership of ACCA, CPA Australia, or CA ANZ can indicate you’re an accounting practice (not mandatory).

Conveyancing (Non‑Lawyer) — Who it’s for

3

Broker the purchase, sale, or transfer of real estate

  1. Typically serve individual Australian residents

  2. Funds: Only handle customer funds directly related to real estate transactions

  3. Exclusions: overseas property; self‑dealing property (no developers); fully remote self‑service; acquisitions/transitions; large groups/foreign branches/subsidiaries

Jewellery Businesses — Who it’s for

4

Buy/sell precious stones, metals, or products for physical currency (cash) transactions of $10,000 or more (incl. linked transactions)

  1. Operate as a jewellery business and do not accept virtual assets (e.g., crypto) for these sales

  2. Typically serve individual Australian residents

  3. Exclusions: fully remote self‑service; acquisitions/transitions; large groups/foreign branches/subsidiaries

  4. Scope note: This kit is designed for businesses accepting regulated cash transactions from individual customers (others can be directed to alternative payment methods).

Provide professional services (incl. conveyancing and services relating to body corporates and legal arrangements)

  • Personnel delivering designated services hold a legal practising certificate

  • Typically serve individual Australian residents

  • Exclusions: overseas property; self‑dealing property (no developers); fully remote self‑service; acquisitions/transitions; large groups/foreign branches/subsidiaries

Mixed practices: The kit can be adapted where you provide both conveyancing and other professional/legal services.

Legal Practices (Lawyers) — Who it’s for

5

Real Estate & Buyer’s Agents — Who it’s for

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Assist in planning/executing sale, purchase, or transfer of real estate (and related body corporate/legal arrangement steps)

  1. Typically serve individual Australian residents

  2. Must not be a practising lawyer under a practising certificate (legal practitioners use the legal practitioner starter kit)

  3. Funds: Only handle client funds directly related to real estate transactions

  4. Exclusions: overseas property; self‑dealing property (no developers); fully remote self‑service; acquisitions/transitions; large groups/foreign branches/subsidiaries

Not a perfect fit? What to do next

7

If your business or practice doesn’t meet every characteristic, you should still proceed—but your AML/CTF program must be customised to reflect your risks. Larger or more complex operations (e.g., groups, foreign branches, frequent high‑risk customers, remote self‑service, virtual assets, or overseas property) generally need enhanced controls, such as:

  • Broader customer due diligence and EDD triggers

  • More robust KYC/verification (including non‑face‑to‑face risk mitigants)

  • Expanded transaction monitoring rules and threshold/linked transaction detection

  • Tailored high‑risk country and sanctions screening workflows

  • Independent review, enhanced governance, and MI/reporting suited to scale

Reserve an appointment

Explore how our expert AML consultancy services can guide your business through its Tranche 2 obligations. We provide a complimentary, no-obligation consultation to assess your needs and determine if our support is the right fit for you.

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