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AML/CTF Program Kit, edition 2026.1

Last checked 25 September 2026 against the AML/CTF Act compilation C2026C00274, the AML/CTF Rules 2025 (F2025L01026) and the Transitional Rules 2026 (F2026L00393)

The documents a small firm uses to set up and run its AML/CTF program: the risk assessment, the policies, client due diligence forms, registers and a reporting calendar. Four sector editions in Word, for accountants, real estate agencies, conveyancers and legal practices. Each document names the section of the Act or the Rules it answers.

s 26B s 26C s 26F Built on AUSTRAC's starter kits, CC BY 4.0

Before you buy: AUSTRAC's starter kits are free

AUSTRAC publishes free AML/CTF program starter kits, including kits for accountants, real estate agents, conveyancers and the legal profession. If your firm fits AUSTRAC's profile and you have time to customise the documents yourself, they may be all you need. Our kit is built on them, openly and with attribution.

See AUSTRAC's program starter kits (AUSTRAC website, opens in a new window)

See sample pagesPrefer it done for you? See Setup

01 AUSTRAC's kit and ours

How the kit relates to AUSTRAC's free kit

AUSTRAC's starter kits are the base. We adapted their risk assessment, policy, process and form documents under AUSTRAC's Creative Commons licence (CC BY 4.0). Every adapted document carries AUSTRAC's attribution in its footer, in the words shown at the foot of this page. We do not use AUSTRAC's logo, and AUSTRAC has not endorsed anything we sell.

AUSTRAC's free starter kit compared with this kit
Compared on AUSTRAC's starter kit This kit
Price Free A$497 including GST, once
Documents Blank risk assessment, policy, process and form documents, plus a guide to customising them The same structure, adapted, with the legal reference behind each obligation written in
Legal references Explained in guidance on AUSTRAC's website Section, Rules number, date and threshold written into the documents and checked against the authorised text
Sole principal Includes forms for when one person holds both roles One-person mode carried through the documents where the owner is the governing body
Registers and calendar Forms for personnel, clients and reviews Adds a training register, a pre-commencement customer register, a record-keeping index and a one-page reporting and review calendar
Sector documents One kit per sector Four editions in one purchase, each with its own sector documents
Sources AUSTRAC's own pages A sources document listing every instrument and AUSTRAC page relied on, by topic

AUSTRAC's original files are not in our zip. Each edition links to AUSTRAC's free document library for that sector, so you can download the originals from AUSTRAC and compare them with ours:

These links go to the AUSTRAC website and open in a new window.

02 What is inside

The kit, edition by edition

Kit contents, by folder (edition 2026.1)
FolderWord documents
Accountants edition29
Real estate agency edition30
Conveyancer edition31
Legal practice edition31

The zip opens with four files that cover every edition:

  • 00 START HERE.docx: which edition to open, the order of work, the one-person mode, how to fill in the fields, and what to do if you have not enrolled yet.
  • SOURCES AND CITATIONS.docx: every instrument we cite (with its compilation and link) and every AUSTRAC page we relied on, by topic.
  • README.txt: the edition stamp, a map of the folders, the seller and contact details.
  • LICENCE AND ATTRIBUTION.txt: your licence and AUSTRAC's attribution and no-endorsement terms.

Every edition folder then holds documents 01 to 25, listed below, followed by its own sector documents from 26 onwards. Each file name starts with its number, so the lists match the folders. Where the law differs by sector, the shared documents carry the sector's wording: for example, the real estate and conveyancers policies include the settlement-verification clause Rules 5-20, and the legal practices policies include the legal professional privilege clauses. CDD means customer due diligence.

Documents 01 to 25, in every edition

  1. 01

    Designated-service determination and scope note

    s 6 Rules 3-2
  2. 02

    ML/TF (and proliferation financing) risk assessment

    s 26C s 26D s 26P
  3. 03

    AML/CTF policies

    s 26B s 26F s 26G
  4. 04

    Process document: CDD, screening, escalation, reporting and maintenance procedures

    s 28 s 30 s 32
  5. 05

    AML/CTF roles and responsibilities record

    s 26H
  6. 06

    AML/CTF compliance officer: designation, eligibility and fit-and-proper record

    s 26J s 26M Rules 5-14
  7. 07

    Personnel due diligence record (other AML/CTF role holders)

    s 26F(4)(d) Rules 5-8
  8. 08

    AML/CTF training plan and register

    s 26F(4)(e) Rules 5-9
  9. 09

    Onboarding and initial CDD forms: individual or sole trader

    s 28 Rules 6-1
  10. 10

    Onboarding and initial CDD forms: body corporate, partnership or unincorporated association

    s 28 Rules 6-2
  11. 11

    Onboarding and initial CDD forms: trust

    s 28 Rules 6-3
  12. 12

    Onboarding and initial CDD forms: government body

    s 28 Rules 6-4
  13. 13

    Enhanced CDD form

    s 32 Rules 6-20
  14. 14

    Ongoing CDD: periodic review and trigger-event review forms

    s 30
  15. 15

    Pre-commencement customer register and transition plan

    s 36
  16. 16

    Unusual activity report, escalation form, review form and escalations register

    s 41 Rules 5-12
  17. 17

    Suspicious matter and threshold transaction reporting procedure and register

    s 41 s 43 Rules 9-1
  18. 18

    Reporting and review calendar

    s 47 Rules 9-9 Transitional Rules s 17
  19. 19

    Record-keeping index

    s 107 s 111 s 116
  20. 20

    Periodic effectiveness checks pack

    s 26D Rules 5-4
  21. 21

    Maintain-the-program record and annual report to the governing body

    s 26H Rules 5-7
  22. 22

    Independent evaluation plan and response form

    s 26F(4)(f) Rules 5-10
  23. 23

    AUSTRAC enrolment, changes and notices procedure

    s 51B s 51F s 167
  24. 24

    Senior-manager approval and program documentation record

    s 26N s 26P Rules 5-15
  25. 25

    Privacy collection notice for customer due diligence

    OAIC guidance for reporting entities

Sector documents, from 26 onwards

Accountants edition

Built on AUSTRAC's accountant kit. Page for accounting practices

  1. 26

    Designated-service worksheet: company and trust formation, SMSF establishment, registered office, shelf companies, nominee and officer services

    s 6
  2. 27

    Tipping-off procedure with the crime-prevention exception for qualified accountants

    s 123(4)

Real estate agency edition

Built on AUSTRAC's real estate kit. Page for real estate agencies

  1. 26

    Delayed initial CDD and settlement-verification procedure

    s 29 Rules 6-32 Rules 5-20
  2. 27

    Request to verify information form and conveyancer or agent arrangement

    Rules 6-33
  3. 28

    Seller-side and buyer-side onboarding note

    s 6

Conveyancer edition

Built on AUSTRAC's conveyancer kit. Page for conveyancers

  1. 26

    Delayed initial CDD and settlement-verification procedure (conveyancing)

    s 29 Rules 6-32
  2. 27

    Request to verify information form and real estate agent arrangement

    Rules 6-33
  3. 28

    Trust-money determination note (Table 6, item 3)

    s 6
  4. 29

    Other professional services forms and second risk assessment (optional set)

    s 26C

Legal practice edition

Built on AUSTRAC's legal profession kit. Page for legal practices

  1. 26

    Legal professional privilege handling procedure and LPP form register

    s 41(2A) s 43(3)(aa)
  2. 27

    Tipping-off procedure, the crime-prevention exception and retainer termination

    s 123(4)
  3. 28

    Conveyancing forms set and conveyancing risk assessment

    Rules 6-32 Rules 6-33
  4. 29

    Scope note: barristers, mixed practices and practising-certificate routing

    s 6

Want to see the pages first? See sample pages from the kit.

03 How it was checked

Every reference checked against the law itself

Each section number, Rules number, date and threshold in the documents was checked against the authorised text on the Federal Register of Legislation: the AML/CTF Act compilation C2026C00274, the AML/CTF Rules 2025 (F2025L01026) and the AML/CTF Transitional Rules 2026 (F2026L00393). An automated check then refuses any reference that does not appear in those texts, and any statement on our list of known errors, such as section numbers that have been repealed.

Every adapted document carries an edition stamp on its cover. The stamp names the edition and records the Act and Rules compilations it was checked against and the date of the check; the footer carries AUSTRAC's attribution line.

Some of the facts the documents are written to

Examples of dated obligations in the kit
Obligation What the law says Law
Suspicious matter report Within 3 business days of forming the suspicion; 24 hours for terrorism financing; 5 business days where a third party's legal professional privilege may cover some of the information s 41
Threshold transaction report Within 10 business days, for A$10,000 or more in physical currency s 43
First compliance report Covers 1 July 2026 to 30 June 2027; lodged between 1 July and 30 September 2027 s 47 Rules 9-9
First independent evaluation For firms covered by the 29 July 2026 enrolment date: before 30 June 2029, 31 December 2029, 30 June 2030 or 31 December 2030, set by the last two digits of your enrolment identifier Transitional Rules s 17
Customer due diligence records Kept for 7 years after the business relationship ends or the occasional transaction is completed s 111

04 Your part

What you still decide yourself

The kit sets out the documents and the legal references. The decisions about your firm stay with you, as the law intends. You will:

  • Decide which of your services are designated services, using AUSTRAC's guidance and its "check if you may be regulated" tool, and record the result in document 01.
  • Rate your risks: your services, clients, delivery channels and the countries you deal with s 26C, and set your risk appetite.
  • Name your people: the AML/CTF compliance officer, who must be at management level, a resident of Australia and a fit and proper person s 26J, and the senior manager who approves the program s 26P.
  • Choose how you check clients: your verification sources, and how you screen for sanctions and politically exposed persons.
  • Keep only the forms you need, for the kinds of clients you actually have.
  • Approve and date the program before you provide a designated service, and follow it s 26G.
  • Engage an independent evaluator at least once every 3 years s 26F(4)(f). It cannot be the person who wrote your program.

If you would rather we did this work from your answers, that is our Setup service, from A$990 including GST. It includes the kit.

05 Is it suitable for your firm?

AUSTRAC's profile for its starter kits

AUSTRAC wrote its starter kits for smaller firms. For accounting practices, real estate agencies and legal practices, its criteria include:

  • 15 or fewer personnel, including administrative staff;
  • mostly Australian-resident individual clients;
  • no overseas property transactions;
  • no fully remote self-service onboarding;
  • not part of a large reporting group.

The full lists are on AUSTRAC's getting-started page for each kit. For conveyancers, read the list on AUSTRAC's conveyancer kit page (opens in a new window).

AUSTRAC starter kits: getting started

Outside that profile

AUSTRAC says a business outside its profile cannot rely on the starter kit to meet AUSTRAC's regulatory expectations. Our editions are built on the same kits, so you should not rely on ours either. If you are unsure, email [email protected] before you buy.

06 Our promise and your licence

The correction promise

If you find a factual error in a citation, a date or a threshold in any document in the kit, email [email protected]. We correct it and re-issue the document within 5 business days, at no cost.

That is the only promise we make about the documents. We do not promise that using them makes your firm meet its obligations: that depends on how you fill them in and follow them. Your rights under the Australian Consumer Law are not affected.

Your licence, in short

  • One firm. The kit is licensed to the business named on your order (one ABN).
  • Use it inside your firm. You may share it with your staff, your compliance officer, your independent evaluator, your professional adviser and AUSTRAC.
  • Edit it freely. Change, cut, add to and re-brand the documents.
  • Keep AUSTRAC's attribution on the parts adapted from AUSTRAC's material.
  • Do not resell or pass it on to another business, and do not use it to supply kits or compliance services to others.

The full licence is in our terms.

07 Straight answers

Questions buyers ask

Why pay when AUSTRAC's kit is free?

You may not need to. AUSTRAC's kit is a complete package of blank documents, with a guide that walks you through customising them yourself (the accountant kit's checklist has four parts and about 17 steps). Our editions do part of that work for you: the section, Rules number, date or threshold behind each obligation is written in; the one-person mode is set up for a sole principal; several registers and a one-page calendar are added that are not in AUSTRAC's kit; and the sources document lists the AUSTRAC page behind each topic. Each edition links to AUSTRAC's free document library for your sector, so you can compare our documents with the originals.

Which edition do I use?

The one for your sector. A legal practice that also does conveyancing uses the legal practice edition, because AUSTRAC's legal profession kit covers conveyancing done under a practising certificate. A conveyancing practice that does not operate under a legal practising certificate uses the conveyancer edition. That is AUSTRAC's own routing.

Is it suitable for my firm?

It is built for the same firms as AUSTRAC's starter kits: for accounting practices, real estate agencies and legal practices, AUSTRAC's criteria include 15 or fewer personnel, mostly Australian-resident individual clients, no overseas property, no fully remote self-service onboarding, and not being part of a large reporting group. AUSTRAC says a business outside its profile cannot rely on the starter kit to meet its regulatory expectations. Because our editions are built on those kits, you should not rely on ours either. Conveyancers: read the suitability list on AUSTRAC's conveyancer kit page.

What format are the documents?

Microsoft Word (.docx) files you can edit, with shaded fill-in fields for your details. Two short plain-text files (a README and the licence) sit alongside them. No logins, no software to install, and no subscription.

Do I get new editions?

This is edition 2026.1, and every document carries that stamp. If AUSTRAC releases a new version of its starter kits, or the Act or Rules change in a way that affects the documents, we publish a new edition. Buyers of edition 2026.1 can download it at no charge. Nothing renews and nothing is billed again.

Can I buy one sector only?

No. One price covers all four editions. Most firms use one. A mixed practice, such as a law firm with a separate conveyancing business, may use two.

Is this an AUSTRAC product?

No. AMLCompliant is Wani Meridian Pty Ltd (ABN 97 701 307 020) trading as AMLCompliant, an independent business. We adapt AUSTRAC's published starter kits under the CC BY 4.0 licence and attribute them on every adapted document. AUSTRAC has not reviewed or endorsed our documents.

Is the kit legal advice?

No. It is general information and editable documents. Deciding which of your services are designated services, and whether the documents fit your firm, is your decision. If your situation is unclear, speak to a lawyer or your professional body.

See all prices on the pricing page, or the sources we rely on across the site.

Sources for this page

Ready to buy

AML/CTF Program Kit

All four sector editions — accountants, real estate agencies, conveyancers and legal practices — as editable Word documents. No subscription.

Prefer it done for you? The set-up service starts at A$990 and includes the kit.

A$497 one-off, includes GST of A$45.18

Buy the kit — A$497

After payment you go straight to your download page.

Independent. Not affiliated with, or endorsed by, AUSTRAC or the Australian Government.