Do I still need a solicitor for AML/CTF Tranche 2 compliance?

Yes. HeadStart Docs products are digital publications that give you a substantial head start, but they must be reviewed and tailored by a qualified solicitor to your specific business circumstances before implementation.

How is HeadStart Docs different from the free AUSTRAC Starter Kits?

AUSTRAC Starter Kits are generic starting points that require significant customisation. HeadStart products are sector-specific, pre-populated with industry-relevant risk factors and scenarios, and include 12 months of AML Portal access for ongoing compliance including screening, record keeping and reporting tools.

What if the AML/CTF rules change after I purchase?

Your digital products are yours to keep. If significant regulatory changes occur, updated versions will be available to active portal subscribers. The AML Portal itself is continuously updated to reflect current AUSTRAC requirements and sanctions lists.

What happens after my 12-month AML portal access expires?

Your documentation is yours forever. To continue using the AML Portal (screening tools, compliance calendar, record keeping), you pay $35 per customer CDD. Cancel anytime — no subscription required.

Is HeadStart Docs a law firm?

No. HeadStart Docs is a digital publisher and platform provider. We sell digital compliance products and portal access. We do not provide legal advice. Referrals for legal advice can be made to our related law firm, HeadStart Counsel.

When does AML/CTF Tranche 2 commence in Australia?

Tranche 2 AML/CTF obligations commence on 1 July 2026. All reporting entities in designated sectors including lawyers, accountants, real estate agents, conveyancers, and trust and company service providers must have their AML/CTF programs in place by this date.

What is included when I sign up?

Every account includes sector-specific AML/CTF program documents covering your ML/TF Risk Assessment, Customer Risk Assessment Matrix, AML/CTF Program (Tranche 2 updates) with Governance, CDD and PDD, CDD Procedures, Client Information Sheet, Tipping Off Prevention Policy, Implementation Plan, Enrolment Guide, Compliance Calendar, Briefing Note for Review with a Solicitor and Decision Trees. You also get Shared CDD/CDD Arrangement documents with e-signature and Reliance Records, plus full AML Portal access (no subscription, cancel anytime). All documents are subject to licence terms and require legal review before use.

What features come with the free AML Portal?

The AML Portal has no monthly subscription fee when you run CDD through us. You can run CDD at a flat $35 rate per customer which includes all screening. The portal provides Transaction Reporting, Smart CDD AI Tools, a Reporting Calendar with Alerts, Secure Data Recording, Audit-Ready Tools, Bulk Historical Onboarding (CSV import), Decision Trees, Risk Management tools, Shared CDD/CDD Arrangements with e-signature, Automated Annual Reporting and more.

What is NOT included?

The program documents (from $249 one-time) cover one sector per account. They exclude Tranche 1 sectors, enrolment with AUSTRAC, lodgement of reports with AUSTRAC, ongoing compliance management, outsourced AML/CTF provider services and legal advice or review. All documents are provided as general information only and require your own legal review and tailoring before use.

What is the difference between Retail and White Label?

Retail products are for single-entity use within your own business while White Label products are for businesses serving other clients, such as consultants, accountants or lawyers, and they want to provide our compliance documents for multiple entities under their own branding.

How long does it take to set up the AML Portal?

You could be set up within a day. Plug & Play Technology walks you through your business details and configures the portal automatically. Starting from our program instead of a blank page saves significant time. Your lawyer then reviews and signs off before you go live. You can change your configuration at any time. No technical knowledge is needed.

Do I have to use Plug & Play Technology?

No. Your program documents are downloadable and you can complete them yourself and take them to your own systems or portal. You do not need to use our AML Portal at all. That said, most users choose Plug & Play because it saves a significant amount of time. Rather than working through each document manually, you answer a set of questions once and the portal configures itself to match your business. For most people it will be the faster and easier option, but it is entirely up to you.

Can I use the free AUSTRAC Starter Kit with your portal?

Yes. If you have used one of AUSTRAC's free starter kits to build your AML/CTF program, you can still sign up for the free AML Portal and run CDD at the flat $35 rate. The portal handles screening, monitoring and reporting regardless of where your program documents came from. That said, AUSTRAC's kits have known gaps in coverage. We published a 45-item audit if you want to compare.

How is HeadStart different from the free AUSTRAC Starter Kits?

AUSTRAC's free kits cover only a handful of sectors and are designed for firms with fewer than 15 staff. They omit entire sectors like TCSPs, virtual address providers, property developers, business brokers and insolvency practitioners. They also lack cross-references to specific sections of the AML/CTF Act, so if you change something it is hard to know whether the change breaks a legal requirement. Our 45-item audit found missing coverage for Reporting Groups (s 26F(5)-(6)), no Sanctions screening processes, no standalone Tipping-off prevention policies and no LPP notification forms. HeadStart documents reference the Act and Regulations throughout so you and your solicitor can cross-check every policy position. They also include free portal access with managed CDD, CDD at the flat $35 rate and Plug & Play Technology that configures your portal in minutes. You get a range of compliance tools including screening and transaction reporting so you are not stuck managing everything in static Word documents.

Why doesn't HeadStart Docs™ cover financial services, gambling or VASPs?

Sectors like financial services and gambling are traditional AML sectors with significant regulatory histories and established provider ecosystems. HeadStart Docs™ is a fresh solution for Tranche 2 only, because Tranche 2 specifically requires fresh technology solutions.

What is your refund policy?

Please view our terms and conditions for full details regarding refunds.

Are HeadStart Docs™ ready to use immediately?

Your documents are ready within minutes via Plug & Play. Starting from our program instead of a blank page saves significant drafting time. We include a structured Briefing Note and requirements mapping table so your lawyer can review and tailor efficiently. Nothing to lose. Your documents are licensed to you permanently. Subject to licence terms.

Do I need a solicitor?

We strongly recommend it, and we make it easy. Starting from our program instead of a blank page saves significant time. We provide a Briefing Note, a requirements mapping table and optional read-only portal access so the review is structured and efficient. If you don't have a lawyer, we can connect you with HeadStart Counsel (related entity, fixed-fee from $1,800+GST) or you can find one via your Law Society. Nothing to lose. Your documents are licensed to you permanently. Subject to licence terms.

Do I need an external AML provider?

This is a question for your solicitor. They can help you determine if your internal systems are sufficient to manage compliance in-house or if engaging an outsourced AML provider is safer for your circumstances.

What happens if I’m not enrolled by 1 July 2026?

AUSTRAC can impose civil penalties of up to $19,800 per day per contravention for failing to enrol or maintain a compliant AML/CTF program. The enrolment portal opens 31 March 2026. Many firms are starting program preparation now so their solicitor has time to review and tailor it before the deadline. This is general information only and does not constitute legal advice. Always seek advice specific to your circumstances.

AML Program from $249. $0/mo Portal with managed CDD. $35 flat CDD per customer. T&Cs apply.Get started

Home

Programs

Portal

Your Tranche 2
AML Compliance Portal

Name: HeadStart Docs
Brand: HeadStart Docs
Price: 679 AUD

$0/mo Portal with managed CDD · AML Program from $249 · $35 flat CDD

Set up in minutes, not days

Ready by 1 July 2026

Cancel anytime

Plug & Play portal setup

100% Australian Owned

Built for Independent Professionals

Updated for 2026 Tranche 2

Built for AUSTRAC Tranche 2

Lawyer-Backed via HeadStart Counsel

Plug & Play Portal Setup

100% Australian Owned

Built for Independent Professionals

Updated for 2026 Tranche 2

Built for AUSTRAC Tranche 2

Lawyer-Backed via HeadStart Counsel

Plug & Play Portal Setup

100% Australian Owned

Built for Independent Professionals

Updated for 2026 Tranche 2

Built for AUSTRAC Tranche 2

Lawyer-Backed via HeadStart Counsel

Plug & Play Portal Setup

100% Australian Owned

Built for Independent Professionals

Updated for 2026 Tranche 2

Built for AUSTRAC Tranche 2

Lawyer-Backed via HeadStart Counsel

Plug & Play Portal Setup

Countdown to Tranche 2

days

Enrolment Opens

days

New Obligations Apply

Failure to enrol or set up AML programs risks penalties of up to $19,800 per day per breach.

Implementation Timeline →

Source: AUSTRAC, How Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws are changing (August 2025)

What's changing?

From 1 July 2026, Australia's AML/CTF regime extends to professional services for the first time. Lawyers, accountants, real estate agents, conveyancers and other sectors will become reporting entities with new obligations.

Every practice providing designated services will need an AML/CTF program, customer due diligence procedures and must enrol with AUSTRAC.

Learn more about Tranche 2

What you actually have to do

Five things. That's the whole list.

AML/CTF compliance comes down to five obligations. Most firms already do parts of this. We handle the rest.

Enrol with AUSTRAC

It's a form. That's it.

We walk you through it.

Have your program ready

We give you one. Free.

Every reporting entity needs an AML/CTF program. Risk assessment, policies, procedures, governance, training. We give you sector programs that you can tailor in minutes.

Program docs from $249, yours forever. Plug & Play setup in minutes.

Know your customers

You already do most of this.

Verify identity, check sanctions lists, assess risk. If you already collect ID from clients, you're halfway there.

$35 inc GST per customer. Includes PEP, sanctions and adverse-media screening.

Monitor transactions

Not as scary as it sounds.

Flag anything unusual. You don't need complex software. You need a process and a place to record it.

Portal tracks it. Alerts when something needs attention.

Report when required

Three report types. All guided.

Suspicious matters, threshold transactions, international transfers — plus annual compliance reporting.

Pre-built report templates.

Starting from our program saves significant time. Set up within a day.

Tranche 2 Sectors*

These industries face new AML/CTF obligations from 1 July 2026. Find your sector below.

*For new Tranche 2 sectors entering the AML regime in 2026 (legal, accounting, real estate etc). Tranche 1 sectors (financial services, gambling, VASPs) are out of our scope at HeadStart Docs™.

How it works

Sign Up. Lawyer Reviews. Go Live.

Sign Up & Set Up

Free account. Sector-specific docs. Portal configured in minutes.

Free signup · guided setup

Lawyer Reviews

Send the Brief and Plug & Play Summary. Or invite them into the portal.

At your pace

Go Live

Sync your portal. Test with a sample customer. You're set up and ready to demonstrate compliance, once your lawyer has reviewed your program.

Instant sync

Pricing

Program packs from $249. Free portal. Pay only for CDD.

Program packs from $249 one-time ($1,500 Group), or bring your own program. Portal is free with managed CDD ($35/customer), or run your own CDD on BYO-API plans from $20/month. No subscriptions. Your documents, reviewed by your lawyer, on your terms. Subject to licence terms.

One-time, yours forever

AML Portal + Program Documents

$249 one-time ($1,500 Group)

Sector-specific program documents, licensed to you permanently — or sign up and bring your own program. Portal is free when you run CDD through us ($35/customer), or run your own CDD on BYO-API plans from $20/month.*

What's Included

Sector-specific AML/CTF program documents (from $249 one-time, yours forever)
Customer management & CDD workflows
3 scheduled sanctions, PEP and adverse media re-screens per customer
Immutable audit log from first login
Seat spend caps per staff member
Plug & Play portal setup
Compliance calendar
Training registry
Guided VOI workflow (you verify and record identity using our step-by-step process)
Bulk onboarding
20 seats included

CDD Pricing

$35

per customer or entity

Your client can pay the $35 directly via Client-Pays CDD.

Individual CDD

PEP screening
Sanctions screening
Adverse media screening
Guided VOI (self-completed)

Company CDD

Sanctions screening
Adverse media screening
ASIC search guide (step-by-step, self-serve via ASIC Connect)

Additional Seats

$10/seat (one-time)

Program pack (one-time)$249

Portal (managed CDD)Free · BYO from $20/mo

Seats20 included

CDD cost$35/customer

Cost to Start$249

* Program packs are $249 one-time ($1,500 Group), licensed to you permanently — or sign up and bring your own program. Portal is free with managed CDD, or run your own CDD on BYO-API plans from $20/month. CDD is $35 per customer. Documents require legal review before use.

Get started today. No subscription. Subject to licence terms.

Free doesn't mean the same thing everywhere.

Some platforms offer free access but charge per search. Others give you templates and wish you luck. We give you the program, the portal, and a price you can predict.

AUSTRAC Free Kits

DIY approach

Program Documents

Limited sectors only

Known gaps in coverage (45-item audit)

Portal / CDD

Not included

Setup Time

Manual setup from scratch*

Annual Reporting

Manual (40+ hours)

Your Data

Your responsibility

Portal-Only Platforms

Free access, pay per search

Program Documents

Auto-generated from template

One-size-fits-all policy generator

Portal / CDD

~$50/customer (per-search pricing)

Costs stack — hard to predict

Setup Time

"A bit of work"

Risk forms, policy setup, staff onboarding

Annual Reporting

"Easy" (their words)

Your Data

Held on their servers

Locked in their ecosystem

Recommended

HeadStart Docs^TM

$249 program + free portal + predictable pricing

Program Documents

All Tranche 2 sectors covered

Sector-specific, lawyer review path included

Portal / CDD

$35/customer — all screening included

One price. No per-search surprises.

Setup Time

Minutes (Plug & Play Technology)

Annual Reporting

Automated

Your Data

BYOS — your data, your storage

Cancel anytime. Your data stays yours.

Setup in minutes, not days

Plug & Play auto-configures your portal from your program. Other platforms make you fill out risk forms and build policies manually.

Your data stays yours

BYOS means 7 years of compliance records live on your storage, not locked in a vendor's portal. Switch any time.

Built for your sector

Auto-generated policies miss sector-specific requirements. Our programs are purpose-built for each Tranche 2 sector.

CDD is $35 per customer, all screening included. Ongoing monitoring at no extra charge. Program packs are $249 one-time ($1,500 Group).

Legal review

Your lawyer is your protection

Structured brief, requirements mapping table and optional portal access. Everything your lawyer needs in one place.

Your Existing Lawyer

Share your program docs and portal access. One click.

Their fees

Find via Law Society

Search official directories. Any lawyer can review efficiently.

Their fees

HeadStart Counsel

Fixed-fee review from a related legal practice.

From $1,800+GST

Separate entity. See disclosure below.

For lawyers: We handle the grunt work, not your role. Every document requires your review. How we work with lawyers →

"I started HeadStart Docs^TM out of spite. The market was offering $8,800 upfront, then $20,000+ a year just to access your own compliance data. For a Word document and a login."

"You own your program. You choose your lawyer. You control your data. That's the point."

Jamie

Founder, HeadStart Docs

Frequently Asked Questions

Common questions from lawyers, accountants and other Tranche 2 professionals

Product Overview

Comparisons & Refunds

Usage & Compliance

Still have questions?

Your Tranche 2
AML Compliance Portal

Countdown to Tranche 2

What's changing?