AUSTRAC's Program Starter Kits: What's Inside and How to Use Them
In January 2026, AUSTRAC published five sector-specific starter kits — the first time any AML/CTF regulator in the world has provided this level of practical support to business. Here's what they contain, who they're for, and how to turn them into your compliance program.
Executive Summary
Every Tranche 2 reporting entity must have an AML/CTF program in place before providing a designated service from 1 July 2026. AUSTRAC's program starter kits provide a practical starting point for small, low-complexity businesses (15 or fewer personnel) in five sectors: real estate, accounting, conveyancing, precious metals and stones, and legal profession.
Each kit contains four documents — a Risk Assessment, a Policy Document, a Process Document, and a Customise Guide — that together form the foundation of your AML/CTF program. The kits follow a three-step lifecycle: Customise (before July), Use (from July), and Maintain (ongoing).
What Are the Starter Kits?
Background and context
When Parliament passed the AML/CTF Amendment Act in November 2024, it brought an estimated 90,000 new businesses into the regime — most of them small firms that had never dealt with anti-money laundering compliance before. AUSTRAC recognised that telling a three-person conveyancing practice to “develop an AML/CTF program” without guidance would be impractical and potentially set businesses up to fail.
In January 2026, AUSTRAC published five sector-specific program starter kits. In the words of AUSTRAC CEO Brendan Thomas, the kits mark the first time that any AML/CTF regulator anywhere in the world has provided this level of practical support to businesses entering the regime.
The kits are designed for small, low-complexity businesses that meet specific suitability criteria (typically 15 or fewer personnel, Australian-resident clients, not regularly dealing with high-risk customers). Larger or more complex businesses will need to build custom programs — but even they can use the starter kits as a reference point.
Important: The starter kits are a starting point, not a finished compliance program. AUSTRAC is explicit that you cannot rely on the kit alone. You must customise it to your business, have it approved by your senior manager, and maintain it as your business and risks evolve.
The Five Sector Kits
Click each sector for suitability criteria and links
The Four Documents Inside Each Kit
What they contain and which Rules they map to
Regardless of sector, every starter kit contains the same four documents. Once customised to your business and approved by your senior manager, these documents form your AML/CTF program. They must be version-controlled, dated, and retained for 7 years.
Identifies the money laundering, terrorism financing, and proliferation financing (ML/TF) risks your business may reasonably face in providing its designated services.
Three parts that define what your business must do and when. This is the document that your governing body (senior manager) must approve.
Standard operating procedures (SOPs) that tell your staff exactly what to do in each situation. This is the document staff use day-to-day.
A step-by-step guide to tailoring the starter kit to your specific business. This is not a compliance document itself — it is the instruction manual for turning the kit into your program.
The Three-Step Lifecycle
Customise, Use, Maintain
AUSTRAC structures every starter kit around a three-step lifecycle. This is not a one-time exercise — it is a continuous cycle. You customise your program before 1 July 2026, use it from that date, and maintain it for as long as you provide designated services.
Customise
Before 1 July 2026Download the starter kit for your sector. Follow the Customise Guide to tailor the Risk Assessment, Policy Document, and Process Document to your specific business. Assign personnel roles, complete PDD, set your risk appetite, and get senior manager approval.
Use
From 1 July 2026Apply your AML/CTF program to every designated service you provide. Conduct CDD on every new customer before providing the service. Monitor ongoing relationships. Report suspicious matters to AUSTRAC. Keep records.
Maintain
OngoingYour AML/CTF program is not a set-and-forget document. You must regularly review and update it to ensure it remains effective and reflects changes to your business, risks, and the law.
When the Starter Kit Is Not Enough
Suitability limits and when you need a custom program
The starter kits are explicitly designed for small, low-complexity businesses. AUSTRAC provides suitability criteria for each sector kit, and if your business does not meet those criteria, you should treat the kit as a reference but build a more comprehensive program. You may need a custom program if:
If any of these apply, AUSTRAC's guidance is clear: you can consider whether parts of the starter kit may be adapted, but you cannot rely on it to meet AUSTRAC's regulatory expectations. Your program must reflect the size, nature, and complexity of your business and the risks it faces.
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References & Further Reading
Primary sources
- AUSTRAC — Program Starter Kits — Main Page Link
- AUSTRAC — Real Estate Program Starter Kit: Getting Started Link
- AUSTRAC — Accounting Program Starter Kit: Getting Started Link
- AUSTRAC — Conveyancing Program Starter Kit: Getting Started Link
- AUSTRAC — Legal Profession Program Starter Kit: Getting Started Link
- AUSTRAC — Dealers in Precious Metals, Stones and Products Guidance Link
- AUSTRAC — Media Release — AUSTRAC Backs Newly Regulated Sectors with Release of Starter Kits Link
- Federal Register of Legislation — AML/CTF Rules 2025 — Part 5 (AML/CTF Programs) Link
Need Help Digitising Your Starter Kit?
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Request Early AccessDisclaimer: This article is published by GetPost Labs Pty Ltd, a technology company building compliance software. All content is for educational purposes only and does not constitute legal, financial, or compliance advice. While we make every effort to ensure accuracy, this article may contain errors or omissions. Always refer to the authoritative text on legislation.gov.au and seek professional advice for your specific circumstances. If you spot an error or have a suggestion, please reach out to sumit@getpostlabs.io.