Key Takeaways
- AUSTRAC publishes free Program Starter Kits for real estate, conveyancers, jewellers, accountants and the legal profession.
- The Starter Kits are templates for your AML/CTF program. They don't run CDD, screen clients, or keep audit records for you — you still need to operate the controls manually or with software.
- AUSTRAC states the Starter Kits are designed for small businesses. Larger or more complex businesses should build a program proportionate to their nature, size and complexity.
- A purpose-built AML platform (like AMLTranche) operationalises the Starter Kit — screening, IDV, SMR workflow, 7-year audit log — so the program you sign isn't just sitting in a drawer.
- Both are complementary: the Starter Kit gives you the written program; software runs the controls. Many small businesses use both.
In this guide
What are the AUSTRAC Program Starter Kits? Who they're designed for What's inside a Starter Kit What the Starter Kits don't do AUSTRAC Starter Kit vs purpose-built AML software When the Starter Kit is enough on its own When you'll want software alongside the Kit How AMLTranche maps to AUSTRAC's Starter KitsWhat are the AUSTRAC Program Starter Kits?
AUSTRAC has published sector-specific Program Starter Kits to help small businesses meet their AML/CTF program obligations under the AML/CTF Act. There's one for real estate, one for conveyancers, one for jewellers, one for accountants, and one for the legal profession. Each is free and publicly available on the AUSTRAC website.
AUSTRAC describes each Starter Kit as helping a small business in that sector to create an AML/CTF program. The Kit walks you through getting started, customising the program to your business, using the program, and maintaining/reviewing it over time.
Who the Starter Kits are designed for
AUSTRAC's public guidance is clear that the Starter Kits are intended for small businesses. For example, the Jeweller Program Starter Kit is described as helping "small jewellery businesses" create an AML/CTF program.
If your business is more complex — multi-entity, multi-project, reporting group, significant foreign buyer volume, or you operate across multiple regulated designated services — AUSTRAC expects your program to be proportionate to your nature, size and complexity. The Kit is still a useful starting point, but you'll need to extend it.
What's inside a Starter Kit
The structure of each Kit is broadly similar. Using the AUSTRAC Jeweller Program Starter Kit as an example, the Kit covers:
- Regulation options for dealers in precious metals, stones and products (when you're regulated)
- Getting started: learning what the Starter Kit is and how to use it
- Step 1: customising the program to your business
- Step 2: using your program in practice
- Step 3: maintaining and reviewing your program
- A document library you can draw from
- Examples of dealing with clients
The equivalent real estate, conveyancer, accountant and legal profession Starter Kits follow a similar pattern with sector-specific examples.
What the Starter Kits don't do
The Starter Kit is a template, not a platform
The AUSTRAC Starter Kits give you the written program you're required to have. They do not run customer due diligence for you, screen customers against the DFAT Consolidated List or PEP databases, capture biometric identity verification, store 7 years of tamper-proof audit records, or coordinate SMR lodgement. All of those operational controls still need to happen in your day-to-day business — either manually or with software.
This is why AUSTRAC's guidance frames the Starter Kit as a starting point rather than a complete compliance solution. You still need to implement the program you've documented.
AUSTRAC Starter Kit vs purpose-built AML software
The two are complementary, not competitive. Here's the simplest way to think about it:
- The Starter Kit = the program. A written document describing your ML/TF risk assessment, your policies, your procedures and your controls.
- Purpose-built software = the operation of the program. Running CDD, screening clients, storing records, lodging SMRs, tracking delayed CDD timers, and generating the audit trail.
Most small businesses using the Starter Kit will still need some form of system to actually run the controls it describes. For a sole trader doing 1–2 matters a year, that system can be manual. For a practice doing many files, spreadsheets quickly become a liability.
When the Starter Kit is enough on its own
The Starter Kit by itself (plus manual record-keeping) can work for a very small business with:
- A handful of transactions per year (say, under 20 files)
- Simple client types (individuals, not complex trusts or companies with layered ownership)
- Low foreign buyer exposure (Enhanced CDD rarely triggered)
- Time to manually screen DFAT lists and keep dated records
In this scenario, you follow the AUSTRAC Starter Kit, customise the templates to your business, and run CDD manually — documenting everything in a clearly-organised file system kept for at least 7 years per AUSTRAC record-keeping guidance.
When you'll want software alongside the Starter Kit
Most practising businesses will find manual operation too risky. Consider software when you have:
- More than a handful of files per year
- Any complex client types (companies, trusts, SMSFs) where beneficial ownership needs to be identified and tracked
- Foreign buyers or regular Enhanced CDD requirements
- Multiple staff who need to coordinate on SMRs without tipping off
- A need to share verified CDD with another reporting entity under the reliance framework
- Long-dated files (e.g., off-the-plan) where DFAT lists need to be re-checked across the life of the matter
In each of these cases, manual operation introduces errors, missed re-screens, and evidentiary gaps. The point is not that the Starter Kit is wrong — it's that it stops at the written program. You need a way to execute it.
How AMLTranche maps to the AUSTRAC Starter Kits
AMLTranche is designed to operationalise the AUSTRAC Starter Kits, not replace them:
- Our program generator mirrors the structure of the AUSTRAC Real Estate, Conveyancer and Jeweller Starter Kits — so your program reads the way AUSTRAC expects.
- The controls the Kits describe (CDD, screening, record-keeping, SMR workflow) are pre-wired into the software.
- The 7-year audit trail is built-in. No need to maintain your own filing system.
- Data is hosted in AWS Sydney (ap-southeast-2). Bank-grade encryption, tamper-proof audit log.
Whether you use the AUSTRAC Starter Kit and AMLTranche together, or start directly with AMLTranche's generator, you'll end up with a written AML/CTF program plus the systems to run it.
Frequently asked questions
Is the AUSTRAC Starter Kit free?
Yes. AUSTRAC publishes the Program Starter Kits free on its website. They are available for real estate, conveyancers, jewellers, accountants and the legal profession.
Can I use the AUSTRAC Starter Kit on its own?
AUSTRAC states the Starter Kits are designed for small businesses. If your business is simple and low-volume, the Starter Kit plus manual record-keeping may be enough. Most practising businesses will benefit from software alongside the Kit to run the controls day-to-day.
Will AUSTRAC accept a program based on the Starter Kit?
The Starter Kit is AUSTRAC's own template, so a program that is genuinely customised to your business and based on the Kit is aligned with AUSTRAC's expectations. You must still ensure the program is proportionate to your nature, size and complexity.
What does AUSTRAC expect beyond the program itself?
AUSTRAC expects you to implement the program, not just have it on file. That means conducting CDD, screening clients, lodging SMRs, training staff, keeping records for 7 years, and conducting independent evaluations of the program at least once every 3 years.
Does AMLTranche replace the Starter Kit?
No. AMLTranche operationalises the Starter Kit. We generate a written program mapped to AUSTRAC's structure and then run the controls (CDD, screening, SMR, audit) so your program isn't sitting in a drawer.
Disclaimer: This article provides general information sourced from AUSTRAC's published guidance and the AML/CTF Act 2006. It does not constitute legal advice. Confirm your specific obligations with AUSTRAC or a qualified legal adviser.