AUSTRAC program starter kit: what you still have to customise

The contrast between a template and the kit is AML/CTF program template versus the AUSTRAC starter kit. That post is the difference between the two starting points. This page is the customise checklist after you download. The official steps are on AUSTRAC’s customise page for the accounting kit, and the index of every sector kit is program starter kits. Checked on 2 October 2026. This is general information, not legal advice. It does not reproduce the Word documents. Who the reforms cover is /tranche-2.

Start from the kit that fits

AUSTRAC publishes 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 treat the download as yours. A kit aimed at a small practice of a certain shape is a poor fit for a firm the page excludes. The other sectors have their own customise step. Use the one for your sector. A pointer to the official kits, without the documents pasted in, is AML program starter kits.

The three documents you still edit

AUSTRAC’s customise page names three documents: the risk assessment, the policy document, and the process document. You change them so they reflect your practice model, your services, your clients, and your risks. The same page says that after you customise and approve those documents, they become your AML/CTF program. Putting the firm’s name on the cover, and leaving another practice’s services in the body, is not that step.

The four customise steps after the download

1. Risk. Identify which risks are relevant, how significant they are, and which you are willing to accept. Those decisions are the base for the controls. The writing list for that block, outside the kit, is what goes in an ML/TF risk assessment.
2. Personnel. Assign the AML/CTF roles, make sure the people in those roles are suitable, and plan the training. A one-person practice still writes the name. See the sole trader compliance officer.
3. Clients. Set out how you take on a client, how you apply customer due diligence, how you monitor, and how you respond when the client’s risk changes. The kit’s word for taking on a client is onboarding. The check itself is customer due diligence requirements.
4. Approve. A senior manager approves the customised pack. In a typical small practice that is a principal or the owner. Approval is a dated decision. It is not the time on the download. Then you use the program. The kit’s next page is step 2, use your program.

Get the guide and the three documents from austrac.gov.au. This site does not attach them and does not paste their clauses. AUSTRAC’s own note says the kits are practical guidance for eligible firms, not a substitute for legal advice, and not an interpretation of the law in every circumstance. If the Getting Started page says the kit is not for you, get advice before you adopt it.

Where FreeAML fits

FreeAML is the working layer after the kit, not a replacement for it. Once a senior manager has approved the program, the firm runs the customer checks that program requires and keeps the evidence. The firm suite is A$0. Verification is client-pays by email. Amounts are on FreeAML pricing. The product does not host the starter kit, it does not replace austrac.gov.au, and it does not approve the Word documents.

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