AML Tranche 2 options in Australia: what each tool can cover and what it can cost per year

HeadStart example (Score: 91/100)

• Program documents: Free
• Portal: Free. No ongoing fees.
• CDD: $35 per customer (all screening included)
• Year 1 cost: $0* – program documents and portal are free. CDD at $35 per customer can be passed to your client as a disbursement.
• Year 2+ total: $0* – portal is free. Your only costs are CDD searches which you can pass onto your customer as a disbursement.
• Year 2+ with Client-Pays CDD: $0* – base portal subscription is $0. CDD is your only variable cost at $35 per customer and you can pass this to your client as a disbursement. Your ongoing out-of-pocket portal cost is zero.
• Optional add-on searches available: police check ($55) and bankruptcy/credit search ($20) for personnel due diligence. Training and independent evaluator costs apply regardless of platform.
• In the editorial team's opinion, this model may result in a lower total cost of ownership compared to subscription-based alternatives, depending on your case volume and requirements

*Program documents and portal access are free. CDD searches are $35 per customer but can be passed to your client as a disbursement via Client-Pays CDD. If you choose to absorb CDD costs, your annual spend will depend on your case volume. Optional per-search fees: police check $55 and bankruptcy/credit search $20 for PDD. Excludes training and independent evaluator costs which apply regardless of platform. No monthly minimums. Covers all 12 Tranche 2 sectors.

easyAML example (Score: 65/100)

• Published pricing starts at $179/month + GST for a team of 5 (Starter plan)
• Base subscription: $179 x 12 = $2,148/year + GST
• Starter plan includes 10 KYC and 2 KYB checks per month; additional verifications cost $20/KYC and $40/KYB + GST
• Australian Institute of Conveyancers endorsed partner

Confirm total annual cost including CDD charges directly with the vendor. Subscription model with ongoing commitment required.

First AML example (Score: 50/100)

• Pricing is not publicly published. Quote-based enterprise pricing.
• Entry-level tier requires minimum ~400 individuals/year or ~100 complex entities/year
• Strong enterprise features: 300+ corporate registries and complex entity verification
• REIA exclusive partner for real estate. 6 of top 10 AU law firms as clients (per First AML). Preferred partner of REIV and REIWA.

Best suited for mid-to-large firms with higher verification volumes. Contact First AML directly for pricing.

InfoTrack example (Score: 54/100)

• Platform access is free (no subscription fees or upfront costs)
• Pay-per-search model, similar to existing InfoTrack property searches
• Includes training modules, risk profiling and PMS integration (LEAP and Smokeball are sister companies under ATI Group)
• Includes guided compliance workflows; confirm the scope of program documentation features directly with InfoTrack

Per-search pricing not publicly published. Confirm with InfoTrack. You will need a separate AML program and governance framework.

TrustEasy example (Score: 60/100)

• Starter plan: $1,200/year for up to 2 users + $330 one-off onboarding
• Includes risk assessment tools, policy drafting, training, CDD and reporting
• Primarily accounting sector. Other sectors available via related TrustSoft brand. Integrates with Xero Practice Manager.
• In beta since January 2026

Annual subscription model. TrustEasy is primarily for accounting firms. Related TrustSoft brand serves other sectors.

APLYiD example (Score: 51/100)

• PAYG pricing model (confirm current per-case pricing directly with APLYiD)
• Costs scale with your case volume
• Strong biometric ID verification (under 90 seconds)

Primarily an identity verification specialist. Confirm what is included in a "case" and whether program management, governance and monitoring are included or require separate tools.

1. Portal access that expires

Based on publicly available information at the time of writing, some providers appear to charge significant upfront fees for "portal access" that expires on a set date. If true, this could mean paying before your obligations commence, and you may need to pay again to retain access. Confirm current pricing and terms directly with any provider.

Consider: With HeadStart Docs, you get free compliance documents. Your documents are licensed to you permanently. No expiring access.

2. Static templates at premium prices

Some providers sell downloadable document templates with prompts for self-tailoring but no automation, no screening tools and no onboarding workflow. Pricing varies — confirm current pricing and inclusions directly with each provider.

Consider: HeadStart Docs™ provides free documents for Tranche 2 sectors (requiring lawyer review and tailoring to your circumstances). The same document types, at no cost.

3. Textbooks are not compliance programs

Some businesses purchase AML/CTF textbooks (such as the Thomson Reuters ProView eBook at $199) expecting it will help them become compliant. A textbook explains the law. It is not a risk assessment, not an AML/CTF program and not something you can show AUSTRAC as evidence of compliance.

Consider: If your budget is limited, spend it on documents you can actually use, not reference material that sits on a shelf.

4. Consulting services vs. document products

Firms like AML Experts focus on bespoke consulting, audits and legal advice. These services are valuable but are priced for hours of professional time.

Consider: HeadStart Docs™ provides free compliance documents, not hourly consulting. Get your documents in place first, then engage a consultant or lawyer for review if you need tailored advice.

5. Ecosystem lock-in

Some providers may operate as part of a wider ecosystem: technology, consulting, training and outsourced compliance under connected brands. If you adopt a platform that bundles these services, switching away could mean losing access to the consulting, training and support network built around it. This is a general consideration, not a claim about any specific provider.

Consider: HeadStart Docs™ is independent. You choose your own lawyer, your own training provider and your own consultant. Your documents are yours to use under licence. Cancel anytime.

6. Subscription creep vs. one-time ownership

Some platforms start at $179/month or more. That is $2,148+ per year (though some plans include a limited number of verifications). Over three years, a $179/month subscription costs $6,444+, and you lose access if you stop paying. A "free until July 2026" offer still becomes a subscription after July.

Consider: HeadStart Docs™ program documents are free. Your documents are licensed permanently. Portal access is free. $35/customer CDD is pay-as-you-go with no minimum.

7. Operational tools are not compliance programs

Some providers primarily offer CDD screening, identity verification and monitoring. The scope of program documentation, risk assessments, policies and governance features varies between providers. Confirm what is included directly with each provider. An onboarding tool without a program behind it is like running a practice without a trust account policy.

Consider: Check whether your chosen tool includes the governance layer (AML program, risk assessment, policies, decision trees and compliance calendar) or just the operational layer (screening, CDD and monitoring). You need both.

Disclaimer

Based on publicly available data as at 4 March 2026. Information may have changed after this date. HeadStart Docs™ provides digital products and general information only. We do not make any representation or warranty that any content is accurate, complete, current, error-free, or fit for any particular purpose, and content may be inappropriate, incomplete, inaccurate, or not suited to your circumstances. This page is not legal advice and should not be relied on as legal advice. Pricing and inclusions change; confirm current pricing and scope directly with each provider before relying on any figure.

The scores in this table are subjective editorial opinions by the HeadStart Docs™ editorial team, not independent or objective assessments. HeadStart Docs™ is one of the options assessed. Each option is scored across 10 dimensions based on publicly available information at the time of writing. Your own assessment may differ based on your needs and priorities.

You should obtain independent legal advice and ensure your documents and processes are reviewed and tailored for your business and risk profile before relying on them. If you require legal advice, HeadStart Counsel may be able to assist under a separate engagement (fees apply).

All product names, logos and brands mentioned on this page are the property of their respective owners. Use of these names is for identification and comparison purposes only and does not imply any affiliation with or endorsement by the respective trade mark owners. HeadStart Docs Pty Ltd is not affiliated with, endorsed by or associated with any of the providers listed.