---
title: "AML Tranche 2 Tools: Cost Comparison 2026 | HeadStart Docs™"
description: "Compare 17 Tranche 2 AML options in Australia with compliance pillars coverage and estimated annual costs. Based on publicly available information. Includes First AML, easyAML, InfoTrack, TrustEasy, RealAML and more."
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Last updated: 1 September 2026 • Comparison Guide 

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

Compare 17 Tranche 2 AML options in Australia using compliance pillars and estimated annual costs. Based on publicly available information at the time of writing. Includes new entrants for 2026: First AML, easyAML, InfoTrack, TrustEasy, RealAML and more.

If you are preparing for AML/CTF Tranche 2, you will find a mix of "starter kits", software platforms, managed programs and standalone screening tools. These options do not all cover the same parts of the work.

This page compares options using four compliance pillars:

1.  Program and governance
2.  Onboarding and CDD
3.  Screening
4.  Reporting and evidence

## Assumptions used for annual cost examples

To compare apples with apples where possible, the annual cost examples below use per-case pricing where published. Actual annual spend depends on your case volume.

Annual spend figures exclude solicitor review, independent audits, internal compliance officer time and external advisory costs, unless a vendor's pricing explicitly bundles those services (in which case we flag it as not apples-to-apples).

## Compliance pillars comparison (with annual spend)

Strong coverage 

Partial coverage, optional, or scope varies 

\- Not a core feature, not evidenced, or not included 

Option

Score /100

Program / governance

Onboarding / CDD

Screening

Reporting / evidence

Estimated annual spend (AUD)

HeadStart Docs (Standard Firm)

91

Program documents + free portal. $35/customer CDD (all screening included).

AUSTRAC starter program kits

44

\- 

\- 

\- 

$0 (free). Comprehensive starter frameworks for small, low-complexity businesses. Not all Tranche 2 sectors have dedicated kits yet

First AML (Source platform)

50

Quote based. Enterprise pricing; entry tier min ~400 individuals or ~100 complex entities/yr

Scantek (easyAML)

65

From $179/month + GST ($2,148+/yr). Starter plan includes 10 KYC + 2 KYB checks/month; additional verifications extra

InfoTrack AML/CTF Compliance Centre

54

Free platform access, pay-per-search. Includes guided compliance workflows; confirm program documentation scope directly with InfoTrack

TrustEasy (primarily accountants)

60

From $1,200/year + $330 onboarding. Primarily accounting sector (other sectors via TrustSoft brand). In beta since January 2026

RealAML (law firms)

56

\- 

Pay-per-use from $7/verification. Primarily a verification/screening tool; program and governance capabilities may be limited

Sophie Grace (Tranche 2 Portal)

35

\- 

\- 

Upfront portal access fee (confirm current pricing directly with Sophie Grace). Includes consultation

Sophie Grace (Document Packs)

35

\- 

\- 

Document packs available (confirm current pricing directly with Sophie Grace). Downloadable templates with prompts for self-tailoring

Arctic Intelligence (AML Accelerate)

45

\- 

\- 

From USD $2,500/year subscription (confirm current pricing directly). No ID verification included

APLYiD

51

PAYG pricing (confirm current per-case pricing directly with APLYiD)

AML Square

49

Quote based. Global platform with AI-powered screening

AML Sorted (managed program)

48

\- 

From $500/month = $6,000 per year. Bundles tailored programs, support and audits

AMLHUB

52

From NZD $100/month

AML Experts

40

\- 

\- 

\- 

Quote based. Typically focused on bespoke legal advice/audits

Moody's / LexisNexis (enterprise screening)

45

\- 

Quote based. Enterprise-grade screening data and tools

Thomson Reuters (ProView eBook)

15

\- 

\- 

\- 

\- 

eBook available (confirm current pricing directly). A textbook only. No templates or software

## How to interpret the table

### 1) Program and governance

This pillar is about documented governance and internal controls, plus maintaining your documentation over time. AUSTRAC has released free starter program kits to help small, low-complexity businesses (typically 15 or fewer personnel) develop a risk assessment and AML/CTF policies. These kits are comprehensive frameworks but are designed for small, low-complexity businesses and require customisation. Not all Tranche 2 sectors have dedicated kits yet — at the time of writing, sectors such as property developers and insolvency practitioners do not have dedicated starter kits, though AUSTRAC has indicated sector-specific guidance for other industries will follow.

HeadStart Docs supports a documentation-first approach through a digital product pack. The pack includes an implementation plan, AML Portal access (base subscription $0) with seats and $35/customer CDD.

### 2) Onboarding and CDD

This pillar is about operational intake and due diligence processes. Many businesses choose software that handles onboarding workflows, verification steps, and record keeping. HeadStart's AML Portal includes CDD workflows at $35 per customer, covering KYC and KYB for that case with all screening included. No monthly minimum.

### 3) Screening

Screening is often split into:

-   Sanctions and watchlists
-   PEPs
-   Adverse media

Some providers bundle screening into an onboarding platform, while others provide data and screening tools that can be integrated into workflows.

HeadStart includes PEP, Sanctions and Adverse Media screening bundled into the $35/customer CDD fee with jurisdiction screening included.

Moody's and LexisNexis are examples of enterprise-grade screening data and tools that organisations may use for sanctions, PEP and adverse media screening. These are often part of a broader compliance stack.

### 4) Reporting and evidence

This pillar is about being able to evidence what you did, when and why. Many platforms claim to be "audit ready" by logging onboarding actions, screening results and escalations. AUSTRAC provides reporting systems but AUSTRAC starter kits are not "reporting and evidence" tools.

When comparing options, ask:

-   Can I export an evidence trail for a matter?
-   Can I show approvals and escalation steps?
-   Can I retain records in the format and retention period required for my circumstances?

## Apples-to-apples annual cost examples

### 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.

## What to look out for when comparing options

### 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.

## Subscription vs. permanent access

When comparing options, consider whether you are paying for ongoing access (subscription) or getting permanent documents you can use indefinitely.

### Subscription model

-   Pay monthly or annually for access
-   If you stop paying, you may lose access to your documents or portal
-   Ongoing cost regardless of usage
-   Often includes support and updates

### Free model (HeadStart Docs)

-   Program documents are free
-   Documents are licensed to you permanently and can be used indefinitely
-   PAYG pricing for ID checks means you only pay for what you use
-   No monthly minimums. Cancel anytime

**Portability:** The HeadStart Docs™ AML Portal is designed to work hand in glove with your program documents. But if you want to take your documents and run your program on another platform or build your own system, we won't stop you. Your documents are licensed for your ongoing use. Cancel anytime, subject to licence terms.

## How to choose the right mix for your business

Most businesses use a mix rather than a single product:

-   AUSTRAC starter kits for baseline documentation (free), plus a workflow tool for onboarding and screening
-   A digital product pack to accelerate documentation and implementation planning, plus an onboarding and screening tool to operationalise checks
-   Enterprise screening data and tools (Moody's, LexisNexis) if you have higher volumes or complex screening requirements

If you want a structured starting point, [explore HeadStart digital products by sector](/programs). If you want legal review of your documents and processes, [HeadStart Counsel](/programs) may be able to assist under a separate engagement.

## Links (provider websites and references)

-   [AUSTRAC](https://www.austrac.gov.au/about-us/amlctf-reform/whats-coming-soon-help-you)
-   [First AML](https://www.firstaml.com/au/plans-and-pricing/)
-   [easyAML (Scantek)](https://easyaml.com/pricing/)
-   [InfoTrack AML/CTF Compliance Centre](https://www.infotrack.com.au/aml-ctf-compliance-centre/)
-   [TrustEasy (primarily accountants)](https://trusteasy.com.au/aml-ctf-compliance-for-accounting-firms/)
-   [RealAML](https://realaml.com/en-AU/s/home)
-   [APLYiD pricing (Australia)](https://aplyid.com/au/pricing)
-   [AML Square](https://amlsquare.com/)
-   [AML Sorted](https://www.amlsorted.com/solution)
-   [AMLHUB (NZ)](https://amlhub.co.nz/)
-   [Sophie Grace](https://sophiegrace.com.au/)
-   [Arctic Intelligence](https://arctic-intelligence.com/)
-   [AML Experts](https://amlexperts.com.au/)
-   [Moody's](https://www.moodys.com/)
-   [LexisNexis Risk Solutions](https://risk.lexisnexis.com/)
-   [Thomson Reuters ProView](https://legal.thomsonreuters.com.au/products/proview/)

### 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.

[

Read our complete Tranche 2 Guide

Key dates, affected sectors, obligations and how to prepare







](/tranche-2)

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[Implementation Timeline Key dates and milestones for Tranche 2 compliance ](/timeline)[Readiness Test Assess your compliance readiness in 2 minutes ](/risk-calculator)[Sanctions Screening Search Australian sanctions lists and country risk ](/sanctions-search)

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HeadStart Docs™ is a digital publisher and platform provider. We sell digital compliance products including publications and portal access to our AML Portal; we do not provide legal advice or services. The content on this website and in our products is for general information purposes only, does not consider your individual and business circumstances, and should not be relied on as legal advice. Referrals for legal advice can be made, on request, to HeadStart Counsel, the registered trading name of Astris Law Pty Ltd, a related incorporated legal practice with the same director and beneficial owner as HeadStart Docs. You are free to engage any legal practitioner of your choice.