AML/CTF program template versus the AUSTRAC starter kit

People search “aml ctf program template” because they want a document they can send somewhere. AUSTRAC’s answer is a starter kit you edit, not a file you lodge untouched. The index is program starter kits. The instruction, in the accounting kit, is step 1: customise your program. Checked on 2 October 2026. This is general information, not legal advice, and it does not reproduce AUSTRAC’s documents. What the finished writing has to contain is the AML/CTF program. Who the reforms cover is /tranche-2.

What the starter kit is

AUSTRAC publishes program starter kits for eligible accounting, conveyancing, legal, real estate, and dealer businesses. Each kit has a Getting Started page that says who it is for. Read that before you download. A kit aimed at a small practice of a certain shape is a poor fit for a firm the page excludes. Forcing it on is not compliance.

Step 1 tells you to customise the risk assessment, the policy document, and the process document so they reflect your services, your clients, and your risks. The accounting page says that after you customise and approve those documents, they become your AML/CTF program. The other sector kits have their own step 1. Use the one for your sector. A pointer to the official kits, without the documents pasted in, is AML program starter kits.

What a template is

A template is any other set of headings: an adviser’s pack, a sample from a talk, or the drafting aid on the free program template. It can show you the shape. It is not AUSTRAC’s starter kit. Do not tell a reviewer, a client, or AUSTRAC that a file is the starter kit unless you downloaded that kit from austrac.gov.au and then customised that download. Do not put a government look on a document this site generated.

Do not file the Word document unchanged

The customise guide on the accounting kit is a Word file, and so are the documents it tells you to edit. Download them from AUSTRAC if the Getting Started page says the kit fits. Then change them. Putting the firm’s name on the cover, and leaving another practice’s services in the body, is not customising. Deleting the services you do not provide, naming your compliance officer, and writing the risks of this client base is the work.

• There is no step where the untouched Word file is uploaded and the program obligation is finished. Enrolment is a separate job in AUSTRAC Online. The program is the document you keep and use.
• A senior manager approves the customised pack. In a small firm that may be the owner. Approval is a dated decision, not the download time on the file.
• If a clause does not describe a service you provide, take it out. If a service you do provide is missing, write it in. The kit is a start. The Act is not inside the Word file as a shortcut.
• This page does not attach AUSTRAC’s files and does not paste their clauses. Get the documents from austrac.gov.au.

AUSTRAC’s guidance is their explanation of the law. It says, in substance, that it is general information and not a substitute for legal advice. A template has the same limit. If the firm is outside the kit’s suitability note, get advice before you adopt it.

Where FreeAML fits

FreeAML operationalises the program after you have one. When the approved document says a customer must be checked, the firm sends that check by email. The firm suite is A$0. Verification is client-pays. Amounts are on FreeAML pricing. The product keeps the evidence of the check. It does not host the starter kit, it does not replace austrac.gov.au, and it does not approve the Word document. The kit remains free from AUSTRAC. The template on this site remains a draft you still have to edit.

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