AML program template: starter kit first, then software
An AML program template is useful after you customise the AUSTRAC starter kit. Software does not replace that order.
Quick answer
Start with the AUSTRAC starter kit for your sector and customise it. A downloaded template is not a program until the firm approves the parts that describe its own services and risks. Software then runs the checks that program names. The firm suite is A$0. The client pays the check.
People search “aml program template” when a firm wants a Word file and a login on the same afternoon, and is about to approve a template it has not read. Checked against AUSTRAC’s program starter kits on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The comparison between a template and the kit is AML/CTF program template versus the AUSTRAC starter kit. What you still customise is the starter kit customise note. The sector map is /tranche-2.
The order that holds up
An AML program template is a structure. The AUSTRAC starter kit is the structure the regulator published for a sector, with blanks the firm is told to fill. Starting from a vendor template and never opening the kit is how a firm approves someone else’s client types. The sequence is the kit, then your edits, then the approval, then any software you use to carry out what you approved.
- Open the sector kit first. Accountants, conveyancers, real estate, legal, and dealers do not share one unmodified file.
- Edit the services. Delete services you do not provide. Add the ones you do. An untouched kit describes a generic firm.
- Approve it. A file in a folder is not a program. The senior manager approval is the step that makes it yours.
- Then choose software. Software sends the check and keeps the record. It does not decide your risks.
Template, kit, and software
What each thing is for. This table does not reproduce AUSTRAC’s starter kits.
| Thing | What it can do | What it cannot do |
|---|---|---|
| AUSTRAC starter kit | A sector starting point you must customise | Enrol you, or know your clients |
| A vendor template | Headings and prompts, if you rewrite them | Stand in for the kit you never opened |
| The approved program | The rules your staff follow | Update itself when you add a service |
| Check software | Email the client a link and return a result | Appoint your compliance officer |
Where this page stops
This page is the sequence. It is not a rewrite of the program contents. What Tranche 2 firms put in writing is the AML/CTF program page. FreeAML’s own boundary, platform versus a subscription promise, is what a free AML tool should include.
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. A program is not a per-check fee. Once the program requires verification, that verification is client-pays. Confirm the live amounts on FreeAML pricing. FreeAML does not approve your program or turn a template into one.
📚 Related Resources
Free KYC Check →
Verify customer identity in 60 seconds. Government ID + AML screening.
Free AML Program →
Board-ready AML/CTF Program template. All 10 AUSTRAC sections included.
Risk Assessment Generator →
AI-powered ML/TF risk assessment. 20-page compliant report in 5 minutes.
Free AML Training →
Online courses for staff. CPD-certified certificates included.
AUSTRAC Reporting Tools →
File SMRs, TTRs, IFTIs directly to AUSTRAC. Pre-filled forms.
Frequently Asked Questions
Write the program for the services you actually provide.
The firm suite is A$0. The client pays each check the approved program requires.
Open the Tranche 2 guideQuestions: team@freeaml.com.au