Key Takeaways
- AUSTRAC is developing free Program Starter Kits for small, low-complexity Tranche 2 businesses.
- The kits provide a template AML/CTF program — but they don't include the operational tools you need to run it.
- Starter kits don't cover automated sanctions screening, identity verification, CDD workflows, record-keeping systems, or AUSTRAC-format reporting.
- The smart approach: use the starter kit to understand your obligations, then use software to operationalise them.
- Don't wait for the kits — you can generate your risk assessment and AML/CTF program today with AMLTranche for free.
In this guide
What are AUSTRAC's Program Starter Kits? Who are the starter kits for? What do the starter kits include? What the starter kits DON'T cover Starter kit vs compliance software Can you use both together? When will the starter kits be available? Frequently asked questionsWhat Are AUSTRAC's Program Starter Kits?
As part of the AML/CTF reform program, AUSTRAC is developing template AML/CTF programs — called "Program Starter Kits" — for small businesses in newly regulated sectors. The kits aim to reduce the compliance burden for businesses that have never dealt with AML/CTF obligations before.
The concept is straightforward: instead of every small business having to write an AML/CTF program from scratch, AUSTRAC provides a pre-built template that reflects sector-wide money laundering and terrorism financing risk. Businesses can then adapt the template to their specific circumstances.
The starter kits were announced as part of AUSTRAC's commitment to support Tranche 2 entities through the transition period. They're designed to complement — not replace — your own risk assessment and compliance setup.
Who Are the Starter Kits For?
AUSTRAC has been clear that the starter kits are designed for small, low-complexity businesses. In practical terms, this means:
Ideal starter kit user
- Small team (1–5 staff)
- Low transaction volume (a few transactions per month)
- Primarily domestic clients (Australian residents)
- Simple entity types (individuals, not complex trusts or corporate structures)
- Residential property only (not commercial or mixed-use)
- Standard transaction values (not high-value luxury or development sales)
If your business handles trust structures, foreign buyers, commercial property, off-the-plan sales, high-value transactions, or operates across multiple offices, the starter kit template likely won't adequately reflect your risk profile.
What Do the Starter Kits Include?
Based on AUSTRAC's published guidance, the starter kits are expected to include:
- Template AML/CTF program — a pre-written program document covering the core obligations
- Basic risk assessment framework — a simplified risk assessment reflecting typical sector-wide risks
- CDD procedures outline — guidance on what customer information to collect and when
- Reporting obligations summary — what to report, when, and how
- Record-keeping requirements — what records to keep and for how long
These are documents and guidance — they tell you what you need to do. They don't do it for you.
What the Starter Kits DON'T Cover
Gaps you need to fill yourself
The starter kits are templates, not operational tools. They don't provide:
- Automated sanctions screening — you still need a way to screen clients against the DFAT Consolidated List in real time
- Identity verification (IDV) — no biometric or documentary verification capability
- CDD workflow tools — no forms, no client portals, no trust or company onboarding workflows
- Ongoing monitoring — no system for periodic rescreening or risk reassessment
- Record-keeping systems — no 7-year tamper-proof storage, no audit trails
- Suspicious matter report (SMR) generation — no AUSTRAC-format reporting tools
- Threshold transaction report (TTR) generation — no automated cash transaction flagging
- Auction-day delayed CDD workflows — no tracking of 20-business-day deadlines
- Staff training modules — no built-in training, tracking, or annual refresher scheduling
- Tailored risk assessment — the kit provides a sector-wide template, not a risk assessment specific to YOUR business
In other words, the starter kit tells you what to do. You need tools and processes to actually do it.
Starter Kit vs Compliance Software: What's the Difference?
| Capability | AUSTRAC Starter Kit | AMLTranche |
|---|---|---|
| AML/CTF program document | Template (generic) | Generated from your risk profile |
| Risk assessment | Sector-wide template | Business-specific, 5 dimensions |
| Sanctions screening | Not included | Real-time DFAT + PEP |
| Identity verification | Not included | Biometric IDV included |
| CDD workflows | Guidance only | Built-in for all entity types |
| Auction-day CDD | Not included | Auto deadline tracking |
| SMR/TTR reporting | Not included | AUSTRAC-format generation |
| Record keeping | Guidance on what to keep | 7-year tamper-proof storage |
| Staff training | Not included | Built-in modules + tracking |
| Cost | Free | From $59/month |
| Setup time | Self-directed (hours to days) | Under 1 hour |
| Best for | Understanding obligations | Operating compliance daily |
Can You Use a Starter Kit AND Software Together?
Yes — and this is actually the smart approach.
Use the starter kit to understand your obligations and get familiar with the AML/CTF framework. Then use compliance software to operationalise those obligations — automate the screening, CDD, reporting, and record-keeping that the kit can't do for you.
Think of it like this: the starter kit is the instruction manual. Software is the tool that does the work.
With AMLTranche, you can generate your risk assessment and AML/CTF program for free — no credit card, no obligation. If you'd also like to reference the AUSTRAC starter kit when it becomes available, the two approaches complement each other.
When Will the Starter Kits Be Available?
AUSTRAC has indicated the starter kits will be available before 1 July 2026, when Tranche 2 obligations commence. However, exact release dates have not been confirmed.
Our advice: don't wait. You can complete your risk assessment and generate your AML/CTF program today. The compliance deadline is firm, and the starter kits may arrive with very little lead time. Businesses that start now will be in a much stronger position than those waiting for AUSTRAC's templates.
Don't wait for the starter kit — start free today
Generate your tailored risk assessment and AML/CTF program at no cost. No credit card. No obligation.
Start Free → Book a Demo →Frequently Asked Questions
Are AUSTRAC's Program Starter Kits free?
Yes. The starter kits are provided free of charge by AUSTRAC and are designed to help small, low-complexity businesses get started with their AML/CTF obligations.
Can I use a starter kit instead of AML software?
The starter kit gives you a template program document, but it doesn't provide operational tools for day-to-day compliance — automated sanctions screening, identity verification, CDD workflows, record-keeping systems, or AUSTRAC-format reporting. Most businesses will need software or manual processes alongside the kit.
When will the starter kits be available?
AUSTRAC has indicated before 1 July 2026, but exact dates haven't been confirmed. Don't wait — you can generate your risk assessment and AML/CTF program today for free with AMLTranche.
Is the starter kit enough for an agency that handles trusts and commercial property?
Likely not. The kits are designed for the simplest businesses. If you handle trust structures, commercial transactions, foreign buyers, or high-value properties, you'll need a more tailored program that reflects your specific risk profile.
Disclaimer: This article provides general information about AUSTRAC's Program Starter Kits and does not constitute legal advice. Information is based on AUSTRAC's published guidance as of April 2026. You should confirm your specific obligations with AUSTRAC or a qualified legal adviser. AMLTranche helps streamline your compliance workflows alongside your professional advisers.