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What are the AUSTRAC starter kits, and do you need one?
What is the AUSTRAC starter kit, and do you need one?
If your business has just received a notice of AUSTRAC obligations, or your business now falls under Australia's Tranche 2 AML/CTF reforms, which came into effect on 1 July 2026, you've probably come across the term AUSTRAC starter kit. This guide explains what it is, who it's for, and where it falls short for businesses that need ongoing compliance.
What is an AUSTRAC starter kit?
AUSTRAC starter kits are official, sector-specific resources that AUSTRAC has published to help small, low complexity businesses in newly regulated sectors build their first AML/CTF program under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). There isn't one generic kit. Separate kits exist for sectors including accounting, legal services, conveyancing, real estate, and dealing in precious metals and stones, and each is meant to be adapted to your business, not just filled in.
They typically include:
A step-by-step template to build your money laundering and terrorism financing (ML/TF) risk assessment
A template AML/CTF program covering the policies, procedures, systems and controls you need
Customer due diligence (CDD) guidance
Guidance on Suspicious Matter Report (SMR) obligations
An introduction to AUSTRAC enrolment and reporting requirements
AUSTRAC publishes its own kits directly, and they're free to use. Compliance consultants and software providers have also produced their own generic templates to help businesses get started quickly.
Who are starter kits designed for?
AUSTRAC built its kits for "typical" small businesses, not every newly regulated entity. Each kit sets out its own suitability criteria. Starter kits generally suit businesses that are:
Small and low complexity, meeting AUSTRAC's suitability criteria for the relevant sector kit
Newly regulated under the AML/CTF Act since 1 July 2026 and building an AML/CTF program for the first time
Dealing mostly with individual customers who pose a low to medium risk, rather than companies, trusts or foreign nationals
If your business fits that profile, a completed starter kit can become your actual AML/CTF program, not just an orientation tool. If it doesn't fit, the kit isn't designed for you in the first place, however simple it looks.
What are the limits of a starter kit?
Even for eligible businesses, a starter kit is a static document. Once filled in, it can satisfy the requirement on paper, but it doesn't run itself. On its own, a starter kit cannot:
Verify customer identities automatically (KYC/KYB)
Screen customers against sanctions lists or PEP databases
Monitor customers on an ongoing basis as risk profiles change
Generate audit-ready records if AUSTRAC examines your business
Host your AML/CTF program in a version-controlled, accessible format
Scale with your business as customer volumes or complexity grow
For businesses that no longer meet AUSTRAC's suitability criteria, or whose customer base is more complex than the kits assume, a starter kit quickly becomes a compliance gap, not a compliance solution. For everyone else, it's a solid head start, but the day-to-day work of running it manually is still on you.
What does a full AML compliance program require?
Under the AML/CTF Act, a compliant program must include:
A money laundering and terrorism financing (ML/TF) risk assessment tailored to your business and customer base, which is the starting point for your program
AML/CTF policies, procedures, systems and controls that manage and mitigate the risks you've identified (AUSTRAC removed the old requirement to split this into Part A and Part B in the 2026 reforms, so you can structure your program however works for your business, as long as it meets the Act's requirements)
Know Your Customer (KYC) procedures, including identity verification at onboarding
Know Your Business (KYB) verification for corporate and trust customers
Ongoing customer due diligence (OCDD) and transaction monitoring
Suspicious Matter Reporting (SMR) to AUSTRAC within required timeframes
Staff training records and a designated AML/CTF compliance officer
A starter kit template can cover most of this on paper. What it can't do is run the ongoing verification, screening and monitoring that keeps the program compliant in practice. If you've just finished building your risk assessment and program, here's what to do next.
What changed under Tranche 2?
Australia's Tranche 2 AML/CTF reforms extended AUSTRAC obligations, from 1 July 2026, to thousands of businesses that were previously unregulated, including:
If your business falls into one of these categories, you now need a fully operational AML program, not just a starter kit, since these obligations are already in force.
When should you move beyond a starter kit?
Consider a dedicated AML compliance platform when:
You onboard more than a handful of customers a month
Your customer base includes companies, trusts or foreign nationals, which puts you outside AUSTRAC's suitability criteria for a starter kit
You need documented evidence of KYC checks for audit purposes
Your current manual processes are consuming too much staff time
You've grown past the "typical small business" profile AUSTRAC built its kits for
Not sure which camp you're in? Here's how to choose the right AML compliance provider for where your business actually sits.
How Personr goes further
Personr is an end-to-end AML compliance platform built for Australian businesses with AUSTRAC obligations. Unlike a static starter kit, Personr provides:
Automated KYC and KYB verification: verify individuals and businesses at onboarding in seconds
AML screening: checks against global sanctions, PEP and adverse media databases
Ongoing monitoring: real time alerts when a customer's risk profile changes
Centralised policy hosting: your AML/CTF program, versioned and accessible
Risk assessments: structured, auditable templates built for AUSTRAC requirements
Suspicious Matter Reporting support: track and file SMRs without manual spreadsheets
API integration: connect Personr to your existing systems and workflows
Whether you're a small business just getting started or an enterprise scaling your compliance function, Personr consolidates every obligation into one platform.
Summary: starter kit vs AML compliance platform
Capability | AUSTRAC starter kit | Personr |
|---|---|---|
AML/CTF program template | Yes | Yes |
Automated KYC/KYB verification | No | Yes |
Sanctions and PEP screening | No | Yes |
Ongoing customer monitoring | No | Yes |
Audit ready reporting | No | Yes |
Policy hosting | No | Yes |
API integration | No | Yes |
Scalable for Tranche 2 | No | Yes |
Frequently asked questions
Yes. AUSTRAC publishes its program starter kits directly and there's no charge to use them.
No. It's not mandatory. It's a baseline you can adapt, and many businesses choose to build on it rather than start from a blank page.
Only if your business meets AUSTRAC's suitability criteria for the relevant sector kit. If your customer base is more complex, or you're growing quickly, you'll need more than a static template.
You're exposed to civil penalties AUSTRAC can enforce against reporting entities that don't meet their obligations. If you're behind, here's what non-compliance actually costs and where to start closing the gap.
