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Compliance
October 4, 20269 min read

Accountant starter kit: customise, do not file the Word doc unchanged

The accountant AML program starter kit is AUSTRAC's starting point for an accounting firm. You customise it, and filing the Word document unchanged does not make it your program.

Quick answer

Open the kit and delete services you do not provide. Keep the ones you do, including formations, trusts, or nominee work if that is actually your practice. Write your own risks. A senior manager approves the result before software sends a check the client pays.

People search “accountant AML program starter kit” when a tax practice downloads the accountant starter kit and saves it to the compliance folder without editing a line. Checked against AUSTRAC's accountant starter kit, step 1 on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. What every sector still customises is the starter kit customise note. The kits side by side are the starter kits summary. The sector map is /tranche-2.

The download is step zero

An accountant AML program starter kit is written for a type of firm, with blanks the practice is told to fill. A tax practice that saves the Word file and calls a meeting has not finished step 1. The kit still describes services, customers, and channels that may not be yours.

Customising is deletion as much as addition. If you do not form companies, do not sit as nominee, and do not hold a registered office, those rows should not survive untouched. If you do any of them, they have to be in the program in your words.

  • Edit the services. Leave in only designated services this practice provides.
  • Edit the customers. A kit example is not your client list.
  • Write the risks yourself. A generic heat map is not your assessment.
  • Approve it. A file in a folder has no senior manager approval, so it is not the program yet.

Unchanged, edited, approved

Staff need to see three states so nobody confuses a download with a decision. The approved version is the only one that binds the firm. Software that stores a PDF does not supply the approval.

States of an accountant starter kit. This table does not reproduce AUSTRAC's accountant starter kit.

StateWhat you haveWhat you do not have
DownloadedAUSTRAC's example structureYour services or your risks
EditedA draft in your wordsApproval
ApprovedThe program staff must followA document that updates itself
Stored in softwareA copy you can findEnrolment, or the approval you skipped

Where the accountant kit page stops

This page is the accountant kit and the ban on filing it raw. It is not the comparison with a vendor template. That comparison is template versus the starter kit.

Other sectors have other kits. Do not customise the real-estate kit and call it the accounting program.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. The starter kit is not a check and it is not a subscription sitting inside the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not customise the starter kit or approve it as your program.

Frequently Asked Questions

Customise the kit, approve it, then email the client a link.

The firm suite is A$0. The client pays each check the approved program requires.

Open the Tranche 2 guide

Questions: team@freeaml.com.au