Program builder versus a downloaded policy pack

People search “AML program builder vs template” when a firm has a forty-page pack in a folder and a builder login, and is about to treat whichever file is newer as the program. Checked against AUSTRAC's program overview on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The kit-versus-template comparison is AML/CTF program template versus the AUSTRAC starter kit. What customising actually means is how to customise the AUSTRAC starter kit. The sector map is /tranche-2.

Questions, or a pile of headings

A downloaded policy pack is a document with someone else's client types already in the sentences. It can be a decent set of headings if you delete the services you do not provide and write the ones you do. If you do not, you have approved a firm you are not. The risk is quiet, because the pack looks finished.

A program builder asks the questions and assembles text from the answers. That is closer to customising, and it is still not customising if you accept every default. The starter kit for your sector remains the reference for what the regulator expected you to think about. The builder and the pack both sit after that, and both wait on the same approval, and a newer timestamp is not an approval.

• Kit first. The sector starter kit is the starting point. A pack or a builder does not replace opening it.
• A pack looks done. That is the danger. Read the services. If they are not yours, it is not your program.
• A builder looks thorough. Defaults you did not read are still defaults. Clicking next is not a risk assessment.
• Approval is the step that counts. A partner adopts the version the firm will use. Until then you have a draft in two formats.

Pack, builder, and the thing you can actually use

Where the builder-versus-pack page stops

This page is the difference between a builder and a downloaded pack. It is not the full template-versus-kit essay, and it is not the customise checklist. Those are AML/CTF program template versus the AUSTRAC starter kit and how to customise the AUSTRAC starter kit.

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. Neither a builder nor a pack is a per-check fee, and the customer verification the approved program requires is still client-pays. Confirm the live amounts on FreeAML pricing. FreeAML does not approve your program or turn a download into one.

Frequently Asked Questions