Service · done for you

AML/CTF program Setup, done for you

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

You answer an intake questionnaire about your services, people and clients. We draft your AML/CTF program, registers and calendar from those answers, walk you through them, train your staff and hand you an indexed evidence file. One fixed fee, paid once, for firms of up to 15 personnel.

For accounting practices, real estate agencies, conveyancers and legal practices.

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

01 Who it is for

Who Setup is for

Setup suits a firm that provides designated services, fits AUSTRAC's starter-kit profile, and would rather not do AUSTRAC's customising steps itself. That includes:

  • Firms that have enrolled but whose program is thin. Your program is your risk assessment plus your policies s 26B, and it has to be documented and approved by a senior manager s 26N s 26P.
  • Firms that have not enrolled yet. Enrol directly with AUSTRAC first; you do not need us for that. Enrol with AUSTRAC (opens in a new window). Obligations applied from 1 July 2026, and enrolment was due on 29 July 2026 for firms already providing designated services, or within 28 days of a later start s 51B.
  • Firms that have received a notice from AUSTRAC. Answer it by the date the notice gives. Setup does not respond to notices for you.

AUSTRAC said on 28 August 2026 that it "has begun issuing section 167 notices to businesses that appear to be providing designated services but have not enrolled". On 1 July 2026 it said it will take a "pragmatic and proportionate approach", while expecting "sustained effort and progress". AUSTRAC news, 28 August 2026 and 1 July 2026

02 Three bands

Choose the band that matches your firm

Each band is a fixed fee, paid once, including GST. Every band includes the full kit download straight away and the ten deliverables listed below, tailored to your intake. The bands differ by the size of your firm and the mix of your services.

Band 1 · 1–3 personnel

Set-up

A$990 one-off, includes GST of A$90.00

Who it fits

A sole practitioner or a firm of 1 to 3 personnel: one office, one sector, one person in charge, clients mostly Australian individuals.

  • The ten deliverables, tailored to your intake
  • One 60-minute call
  • Training for up to 3 people, logged on your register
  • Client forms for two client types
Start with Set-up — A$990

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

Band 2 · 4–8 personnel

Practice

A$1,490 one-off, includes GST of A$135.45

Who it fits

4 to 8 personnel. For example, an accounting practice with companies and trusts among its clients, or an agency with sales and a rent roll.

  • Everything in Band 1
  • Client forms for all four client types
  • Personnel due diligence records for every AML/CTF role
  • A separate approval pack for your senior manager and governing body
  • An escalation workflow
  • Two calls; training for up to 8 people
Start with Practice — A$1,490

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

Band 3 · 9–15 personnel or mixed service lines

Firm

A$2,490 one-off, includes GST of A$226.36

Who it fits

9 to 15 personnel, two offices, or mixed service lines: developer sales, an SMSF-heavy accounting practice, a conveyancing practice with heavy trust-account work, or a legal practice doing both conveyancing and commercial work.

  • Everything in Band 2
  • A designated-service determination for each service line
  • Delayed-CDD and conveyancer or agent arrangement clauses, where they apply Rules 6-32 Rules 6-33 Rules 5-20
  • A reliance agreement template, if you use one s 37A
  • A transition plan for clients you already had on 1 July 2026 s 36
  • A brief for your independent evaluator, with the date
  • A check-in 30 days after delivery
Start with Firm — A$2,490

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

Not sure which band fits? Email [email protected] with your headcount and your services before you pay. All prices, compared with the kit and AUSTRAC's free starter kits, are on the pricing page.

03 What you receive

The ten deliverables

Every document is built on AUSTRAC's starter-kit documents, tailored to your answers, dated and version-controlled. Each one names the law it answers.

Setup deliverables and the law each one answers
No. Deliverable What it records for your firm Law
1 Designated-service determination and scope note Which designated services you provide, from when, and which services are outside. The decision is yours; we record it with AUSTRAC's guidance page for each s 6 Rules 3-2
2 ML/TF risk assessment Ratings for your actual services, clients, delivery channels, countries and cash exposure, and your risk appetite s 26C s 26D
3 AML/CTF policies Personnel, client and maintenance sections completed with your roles and choices, including one-person mode where the owner is the governing body s 26F s 26G
4 Process document and client due diligence procedures Forms only for the client types you have, your verification sources and screening method, and delayed checks or reliance where they apply s 28 s 30 s 32
5 Registers and forms, filled in Roles, the compliance officer's fit-and-proper record, personnel checks, training, escalations, a suspicious matter and threshold transaction register, and a record-keeping index s 26J s 41 s 43 s 116
6 Reporting and review calendar One page, dated from your approval dates and, for firms covered by the 29 July 2026 enrolment date, your enrolment identifier s 47 Rules 9-9 Transitional Rules s 17
7 Enrolment and compliance officer notice check On a call, you enrol or check your entry on AUSTRAC's roll and the compliance officer notice. You log in; we never hold your AUSTRAC Online login s 51B s 26M
8 Training session and record Training for your people's roles, logged on your register with a refresher date s 26F(4)(e) Rules 5-9
9 Independent evaluation plan The date, the scope and the kind of evaluator you need s 26F(4)(f) Rules 5-10
10 Evidence pack Everything above, indexed, with a map of what AUSTRAC can ask for and which document shows it s 26N s 26Q s 116

04 How it runs

What happens after you pay

  1. You pay, and receive the kit and your intake

    Your download page gives you the full kit straight away, and the intake questionnaire for your sector as a Word file.

  2. You complete the intake

    It asks about your business structure, every service line, your people and their roles, the kinds of clients you have, how you deal with them, the countries involved, cash and trust accounts, your enrolment status and enrolment identifier, and who will be your compliance officer. Email it to [email protected].

  3. We draft and check

    We build your documents on AUSTRAC's starter-kit documents, using your intake as the only source of facts about your firm. Every section, date and threshold is checked against the authorised text, and a person reviews the draft before it goes to you. We send your draft documents within 5 business days of receiving your complete intake.

  4. We talk it through

    A 60-minute call covers your service determination, your risk appetite, any delayed checks or reliance, how your firm is governed, and your enrolment and compliance officer notice.

  5. Your senior manager approves

    Your senior manager approves the risk assessment and policies, and we record the approval and the dates. s 26P Rules 5-15

  6. We train your people

    A session for your staff, logged on your training register. s 26F(4)(e)

  7. You receive the evidence pack

    The finished, indexed documents by download link to your email. You keep every document. Band 3 also has a check-in 30 days later.

A business day is a weekday that is not a public holiday in Victoria. If your intake is incomplete, we tell you what is missing; the 5 business days start when it is complete.

What we do not do

  • Legal advice. We are not a law practice. You decide which of your services are designated services; we record your decision and show the AUSTRAC page behind it. Where the answer is unclear, we say so in writing and suggest a lawyer or your professional body.
  • Act as your compliance officer, senior manager or governing body. Those roles stay inside your firm.
  • Lodge reports for you. You lodge suspicious matter reports, threshold transaction reports and compliance reports.
  • Your independent evaluation. We cannot evaluate a program we wrote. We plan it and you engage an evaluator.
  • Sanctions-law advice, screening services, monitoring or later reviews. These are not part of the fixed fee.
  • Promise an outcome. We do not promise that your firm meets its obligations, any result with AUSTRAC, or freedom from penalties. That depends on your firm following its program.

What we do promise

If you find a factual error in a citation, a date or a threshold in our documents, we correct it within 5 business days at no cost.

Not a fit

More than 15 personnel, or outside AUSTRAC's starter-kit profile: we tell you after we read your intake and refund you in full before any work starts.

Your rights under the Australian Consumer Law are not affected. Refunds and how we handle your intake information are set out in our terms and privacy notice.

05 Straight answers

Questions about Setup

Which band is mine?

Band 1 (A$990): a sole practitioner or a firm of 1 to 3 personnel, one office, one sector, one person in charge, clients mostly Australian individuals. Band 2 (A$1,490): 4 to 8 personnel; for example, an accounting practice with companies and trusts among its clients, or an agency with sales and a rent roll. Band 3 (A$2,490): 9 to 15 personnel, two offices, or mixed service lines, such as developer sales, an SMSF-heavy accounting practice, a conveyancing practice with heavy trust-account work, or a legal practice that does both conveyancing and commercial work. If you are not sure, email [email protected] with your headcount and services before you pay.

What do I get on the day I pay?

Your download page gives you the full kit straight away, plus the intake questionnaire for your sector (a Word file). Complete it and email it to [email protected]. We send your draft documents within 5 business days of receiving your complete intake.

Will you be our compliance officer?

No. Your AML/CTF compliance officer must be your own person: employed or engaged at management level, a resident of Australia, and a fit and proper person s 26J. We prepare the designation and fit-and-proper record, and on the call we check with you that AUSTRAC was notified s 26M.

Do you do the independent evaluation?

No. The evaluation must be independent of the people who wrote your program s 26F(4)(f) Rules 5-10, and we write it. We work out your first evaluation date (for firms covered by the 29 July 2026 enrolment date, from the last two digits of your enrolment identifier Transitional Rules s 17; otherwise from the frequency your policies set, which must be at least once every 3 years s 26F(4)(f)), give you a plan, and in Band 3 prepare a brief for the evaluator you choose.

Is a legal practice more expensive?

No. The legal practice edition handles legal professional privilege in every band: the privilege handling procedure, the 5-business-day clock for a suspicious matter report where a third party's privilege may cover some of the information, the right to refuse a report where you reasonably believe all of it is privileged s 41(2A), and the crime-prevention exception to tipping off s 123(4). A practice that does both conveyancing and commercial work is Band 3, because we tailor two risk assessments and two sets of client forms.

What if we are outside AUSTRAC's starter-kit profile?

We tell you after we read your intake, and refund you in full before any work starts. AUSTRAC's starter kits, and our work built on them, are for firms of 15 or fewer personnel that meet AUSTRAC's suitability criteria.

For sector detail, see the pages for accounting practices, real estate agencies, conveyancers and legal practices, or our guide to enrolling with AUSTRAC.

Sources for this page

Ready to start

Choose your band

Payment opens your intake. The full kit download and your sector's intake questionnaire are available straight away.

Not sure which band fits? Email [email protected] before you pay.

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