--- title: "AUSTRAC Starter Kits vs Paid AML Programs | HeadStart Docs™" description: "Detailed comparison of AUSTRAC's free AML/CTF starter kits vs paid programs. Learn what's included, what's missing and when each option is appropriate for your business." lang: en-AU json-ld: | [ { "@context": "https://schema.org", "@type": "Organization", "name": "HeadStart Docs", "legalName": "HeadStart Docs Pty Ltd", "url": "https://www.headstartdocs.com.au", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png?v=4", "width": 512, "height": 512 }, "description": "AML/CTF compliance digital products and programs for Australian businesses under Tranche 2 regulations. Free program documents and AML Portal. 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We provide digital products for AML/CTF compliance, not legal services." } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Shop", "item": "https://www.headstartdocs.com.au/shop" }, { "@type": "ListItem", "position": 3, "name": "Tranche 2 Hub", "item": "https://www.headstartdocs.com.au/tranche-2" }, { "@type": "ListItem", "position": 4, "name": "Sanctions Search", "item": "https://www.headstartdocs.com.au/sanctions-search" } ] }, { "@context": "https://schema.org", "@type": "FAQPage", "mainEntity": [ { "@type": "Question", "name": "Do I still need a solicitor for AML/CTF Tranche 2 compliance?", "acceptedAnswer": { "@type": "Answer", "text": "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." } }, { "@type": "Question", "name": "How is HeadStart Docs different from the free AUSTRAC Starter Kits?", "acceptedAnswer": { "@type": "Answer", "text": "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." } }, { "@type": "Question", "name": "What if the AML/CTF rules change after I purchase?", "acceptedAnswer": { "@type": "Answer", "text": "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." } }, { "@type": "Question", "name": "What happens after my 12-month AML portal access expires?", "acceptedAnswer": { "@type": "Answer", "text": "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." } }, { "@type": "Question", "name": "Is HeadStart Docs a law firm?", "acceptedAnswer": { "@type": "Answer", "text": "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." } }, { "@type": "Question", "name": "When does AML/CTF Tranche 2 commence in Australia?", "acceptedAnswer": { "@type": "Answer", "text": "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." } } ] } ] --- [Get Started ](/checkout) We use cookies to enhance your experience and analyse traffic. [Privacy Policy](/privacy) Essential OnlyAccept All [Skip to main content](#main-content) [ ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) ](/) [Home ](/) Features [Programs ](/programs) Resources Sectors [Log in ](/auth) [Portal](/aml-landing) Educational Guide # AUSTRAC Free Starter Kits vs Paid AML Programs In January 2026, AUSTRAC released official free starter program kits for Tranche 2 reporting entities. This comprehensive guide compares what's included, what's missing, and when each option is appropriate for your business. 12 min read • Updated January 2026 **Disclaimer:** This article is general information only. It is not legal, financial or compliance advice. HeadStart Docs™ provides free compliance documents, not legal services. We do not guarantee the accuracy of information provided. Always seek advice specific to your circumstances from a qualified professional. ## What Are the AUSTRAC Starter Kits? AUSTRAC (Australian Transaction Reports and Analysis Centre) released free starter program kits in January 2026 to help businesses prepare for Tranche 2 AML/CTF obligations. These kits provide foundational documents that reporting entities can customise for their specific circumstances. Each kit contains approximately 35-50 static Word documents and PDF guidance materials, covering policy, procedures, customer forms, personnel forms and effectiveness testing. ## Sectors Covered by AUSTRAC Kits AUSTRAC Kit Available - Legal Professionals (51 documents) - Accounting Professionals (39 documents) - Real Estate Agents (40 documents) - Conveyancers (49 documents) - Precious Product Dealers (36 documents)\* \*Kit limited to physical currency transactions of $10,000+ No AUSTRAC Kit Available - Trust & Company Service Providers (TCSPs) - Property Developers - Insolvency Practitioners - Business Brokers These sectors require alternative documentation sources ## Who AUSTRAC Designed These For According to AUSTRAC's own guidance materials, the starter kits are intended for specific types of businesses: "These starter kit resources are intended as a starting point for smaller reporting entities with 15 or less personnel." \- AUSTRAC Guidance Materials, January 2026 ### Key Criteria for AUSTRAC Kit Suitability - 15 or fewer personnel Sole practitioners and small practices with limited staff - Lower-risk customer profiles Predominantly domestic, low-complexity customer base - New to AML/CTF obligations Businesses entering the regime for the first time under Tranche 2 - Capacity for manual document management Able to customise, maintain and update Word documents manually ## What's Inside Each Kit Each AUSTRAC starter kit contains documents across several categories. Here's a breakdown of what's included: Category Documents Purpose Core Program 3 Policy, Process, ML/TF Risk Assessment Customer Forms 12-17 CDD by entity type, onboarding, periodic reviews, escalations Personnel Forms 5 Staff DD, AML/CTF roles, compliance officer designation Effectiveness Testing 10-12 SMR, TTR, CBM, onboarding, EDD effectiveness checks Guidance Materials 4-6 Getting started guide, examples, document library ## Feature Comparison: Free vs Paid This table compares key features between AUSTRAC's free starter kits and typical paid AML/CTF program solutions: Feature AUSTRAC Free Kit Paid Programs Format Static Word/PDF Digital portal Sanctions Screening Not included Included Training Records Not included Included Compliance Calendar Not included Automated reminders Customer Risk Rating Manual spreadsheet Automated scoring Audit Trail Manual records Automatic logging Regulatory Updates One-time download Ongoing updates Implementation Support None Available ## What the Kits Don't Include While the starter kits provide a solid foundation, they don't include several components that many businesses need for comprehensive compliance: Sanctions Screening No PEP or sanctions list checking capability. You need separate solutions for DFAT, UN and other sanctions lists. Training Management No training modules, completion tracking, or certificate generation for staff AML/CTF training. Digital Workflows Static Word documents require manual processing. No automated form submissions or approvals. Compliance Calendar No automated reminders for periodic reviews, annual reports, or effectiveness testing deadlines. ## Sector-Specific Considerations Precious Product Dealers (Jewellers) The AUSTRAC kit for jewellers specifically covers transactions in **physical currency of $10,000 or more**. If your business also: - Deals in bullion (gold, silver, platinum, palladium) - Provides loans secured on precious items - Accepts virtual assets or cryptocurrency - Provides custodial or storage services for precious items You may need additional documentation beyond what the free kit provides. Legal Professionals The Legal kit includes an LPP (Legal Professional Privilege) form. However, the interaction between LPP and suspicious matter reporting obligations requires careful consideration. The kit provides a starting point but specific advice is needed for your practice. Real Estate Agents The Real Estate kit is designed for standard agency activities. If your business also involves property development activities, the generic kit may not fully address your obligations as a property developer. ## Decision Framework Use this framework to help determine which option may be more appropriate for your business: ### AUSTRAC Free Kit May Be Sufficient If: - Sole practitioner or very small practice (under 15 personnel) - Predominantly lower-risk, domestic customer base - Comfortable maintaining Word documents manually - No requirement for sanctions screening - Your sector has an AUSTRAC kit available ### Consider Paid Programs If: - More than 15 personnel requiring training records - Higher-risk customers or international transactions - Prefer digital workflows over manual documents - Need sanctions screening or PEP checking - Your sector doesn't have an AUSTRAC kit (TCSPs, Property Developers, etc.) - Want ongoing regulatory updates and support ### Key Takeaway AUSTRAC's free starter kits are a valuable resource for smaller, lower-risk reporting entities entering the AML/CTF regime. They provide a legitimate starting point that can be customised to your circumstances. However, they require professional review, customisation and ongoing maintenance. For larger practices, higher-risk profiles, sectors without AUSTRAC coverage, or businesses wanting digital workflows and ongoing support, a more comprehensive paid solution may be more appropriate. HeadStart program documents include [Plug & Play Technology](/plug-and-play) that configures your AML Portal in minutes rather than weeks. You fill in your details, have your solicitor review the completed program, and go live. You can change your configuration at any time. ## Download the Free AUSTRAC Starter Kits Access all five AUSTRAC starter kits in one convenient download, organised by sector. 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