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Reference · AML/CTF programs · AUSTRAC guidance

AUSTRAC’s program starter kits: what is in them, and who each one is for

Inside every kit

A kit is 25 to 44 documents

In January 2026 AUSTRAC published five sector starter kits — real estate, accounting, conveyancing, precious metals and stones, and the legal profession. Each is built from four key documents: a risk assessment, a policy document, a process document and a customise guide. The first three become your AML/CTF program once customised and approved; the customise guide is the instruction manual and is not part of it.

Illustration: a professional reaches for one of five identical folders on a shelf, the one she has chosen picked out in gold
Five kits on the shelf — the sector decides which one is yours
  • Precious metals and stones25
  • Real estate30
  • Accounting34
  • Conveyancing44
  • Legal profession44

Documents per kit

Two kits carry another profession’s forms. The conveyancing kit ships seven accountants’ forms for other professional services; the legal profession kit ships nine conveyancers’ forms for conveyancing. That is deliberate — the form follows the designated service, not the profession of the person providing it, which is the principle Table 6 runs on. They are marked below where they appear.

Precious metals and stones25 documents

Key documents

4

Customised and approved, these become your program. The customise guide is the instruction manual and is not part of it.

  • Customise guide
  • Policy document
  • Process document
  • Risk assessment

Client and customer forms

2

Identity and ownership collected at onboarding — one form per customer type.

  • Initial customer due diligence form - Individual or sole trader
  • Onboarding form - Individual or sole trader

Escalation and unusual activity

5

Used when something does not look right, and to record what you did about it.

  • Enhanced CDD form
  • Escalation form
  • Escalations register
  • Unusual activity report information form
  • Unusual activity report review form

Ongoing monitoring

2

Re-checking a customer on a schedule, or when something changes.

  • Periodic review and update form
  • Trigger event review and update form

Personnel forms

5

Who does what, and the due diligence you run on your own staff.

  • AMLCTF roles form
  • Assign responsibilities form
  • Personnel due diligence for AMLCTF compliance officer form
  • Personnel due diligence form
  • Personnel due diligence where the compliance officer and governing body are the same person form

Maintaining the program

7

The annual and periodic checks that show the program is working.

  • Compliance officer and senior manager effectiveness check form
  • Customer onboarding effectiveness check form
  • Enhanced CDD effectiveness check form
  • Independent evaluation response form
  • Maintain your AMLCTF program form
  • SMR effectiveness check form
  • TTR effectiveness check form
Real estate30 documents

Key documents

4

Customised and approved, these become your program. The customise guide is the instruction manual and is not part of it.

  • Customise guide
  • Policy document
  • Process document
  • Risk assessment

Client and customer forms

5

Identity and ownership collected at onboarding — one form per customer type.

  • Onboarding form - Body corporate, partnership or unincorporated association
  • Onboarding form - Government body
  • Onboarding form - Individual or sole trader
  • Onboarding form - Trust
  • Request to verify information

Escalation and unusual activity

5

Used when something does not look right, and to record what you did about it.

  • Enhanced CDD form
  • Escalation form
  • Escalations register
  • Unusual activity report information form
  • Unusual activity report review form

Ongoing monitoring

2

Re-checking a customer on a schedule, or when something changes.

  • Ongoing Monitoring - Periodic review and update form
  • Ongoing Monitoring - Trigger event review and update form

Personnel forms

5

Who does what, and the due diligence you run on your own staff.

  • AML_CTF roles form
  • Assign responsibilities form
  • Personnel due diligence for AMLCTF compliance officer form
  • Personnel due diligence form
  • Personnel due diligence where the compliance officer and governing body are the same person form

Maintaining the program

9

The annual and periodic checks that show the program is working.

  • Annual report to the governing body form
  • Compliance officer and senior manager effectiveness check form
  • Customer onboarding effectiveness check form
  • Enhanced CDD effectiveness check form
  • Independent evaluation response form
  • Maintain your AMLCTF program form
  • Periodic effectiveness testing summary form
  • SMR effectiveness check form
  • TTR effectiveness check form
Accounting34 documents

Key documents

4

Customised and approved, these become your program. The customise guide is the instruction manual and is not part of it.

  • Customise guide
  • Policy document
  • Process document
  • Risk assessment

Client and customer forms

8

Identity and ownership collected at onboarding — one form per customer type.

  • Initial customer due diligence form - Body corporate, partnership or association
  • Initial customer due diligence form - Government body
  • Initial customer due diligence form - Individual or sole trader
  • Initial customer due diligence form - Trust
  • Onboarding form - Government body
  • Onboarding form - Individual or sole trader
  • Onboarding form - Trust
  • Onboarding form - Body corporate, partnership or unincorporated association

Escalation and unusual activity

5

Used when something does not look right, and to record what you did about it.

  • Enhanced CDD form
  • Escalation form
  • Escalations register
  • Unusual activity report information form
  • Unusual activity report review form

Ongoing monitoring

2

Re-checking a customer on a schedule, or when something changes.

  • Periodic review and update form
  • Trigger event review and update form

Personnel forms

5

Who does what, and the due diligence you run on your own staff.

  • AMLCTF roles form
  • Assign responsibilities form
  • Personnel due diligence for AMLCTF compliance officer form
  • Personnel due diligence form
  • Personnel due diligence where the compliance officer and governing body are the same person form

Maintaining the program

10

The annual and periodic checks that show the program is working.

  • Annual report to the governing body form
  • CBM reporting effectiveness check form
  • Client onboarding effectiveness check form
  • Compliance officer and senior manager effectiveness check form
  • Enhanced CDD effectiveness check form
  • Independent evaluation response form
  • Maintain your AMLCTF program form
  • Periodic effectiveness testing summary form
  • SMR effectiveness check form
  • TTR effectiveness check form
Conveyancing44 documents

Key documents

5

Customised and approved, these become your program. The customise guide is the instruction manual and is not part of it.

  • Customise guide
  • Policy document
  • Process document
  • Risk assessment
  • Risk assessment - Other professional services

Client forms — conveyancing services

9

Used when the service you are providing is a conveyancing service.

  • Initial customer due diligence form - Body corporate, partnership or association
  • Initial customer due diligence form - Government body
  • Initial customer due diligence form - Individual or sole trader
  • Initial customer due diligence form - Trust
  • Onboarding form - Body corporate, partnership or unincorporated association
  • Onboarding form - Government body
  • Onboarding form - Individual or sole trader
  • Onboarding form - trust
  • Request to verify information

Client forms — other professional services

8

Used for the other professional services in Table 6, not the conveyancing ones.

  • Initial customer due diligence form - Body corporate, partnership or associationAccountants’ form
  • Initial customer due diligence form - Individual or sole traderAccountants’ form
  • Initial customer due diligence form - TrustAccountants’ form
  • Onboarding form - Government bodyAccountants’ form
  • Onboarding form - Individual or sole traderAccountants’ form
  • Onboarding form - TrustAccountants’ form
  • Onboarding form - Body corporate, partnership or unincorporated associationAccountants’ form
  • Initial customer due diligence form - Government body

Escalation and unusual activity

5

Used when something does not look right, and to record what you did about it.

  • Enhanced CDD form
  • Escalation form
  • Escalations register
  • Unusual activity report information form
  • Unusual activity report review form

Ongoing monitoring

2

Re-checking a customer on a schedule, or when something changes.

  • Periodic review and update form
  • Trigger event review and update form

Personnel forms

5

Who does what, and the due diligence you run on your own staff.

  • AMLCTF roles form
  • Assign responsibilities form
  • Personnel due diligence for AMLCTF compliance officer form
  • Personnel due diligence form
  • Personnel due diligence where the compliance officer and governing body are the same person form

Maintaining the program

10

The annual and periodic checks that show the program is working.

  • Annual report to the governing body form
  • CBM reporting effectiveness check form
  • Client onboarding effectiveness check form
  • Compliance officer and senior manager effectiveness check form
  • Enhanced CDD effectiveness check form
  • Independent evaluation response form
  • Maintain your AMLCTF program form
  • Periodic effectiveness testing summary form
  • SMR effectiveness check form
  • TTR effectiveness check form
Legal profession44 documents

Key documents

5

Customised and approved, these become your program. The customise guide is the instruction manual and is not part of it.

  • Customise guide
  • Policy document
  • Process document
  • Risk assessment - Conveyancing for the legal profession
  • Risk assessment - Other professional services

Client forms — conveyancing services

9

Used when the service you are providing is a conveyancing service.

  • Initial customer due diligence form - Body corporate, partnership or associationConveyancers’ form
  • Initial customer due diligence form - Government bodyConveyancers’ form
  • Initial customer due diligence form - Individual or sole traderConveyancers’ form
  • Initial customer due diligence form - TrustConveyancers’ form
  • Onboarding form - Body corporate, partnership or unincorporated associationConveyancers’ form
  • Onboarding form - Government bodyConveyancers’ form
  • Onboarding form - Individual or sole traderConveyancers’ form
  • Onboarding form - trustConveyancers’ form
  • Request to verify informationConveyancers’ form

Client forms — other professional services

8

Used for the other professional services in Table 6, not the conveyancing ones.

  • Initial customer due diligence form - Body corporate, partnership or association
  • Initial customer due diligence form - Government body
  • Initial customer due diligence form - Individual or sole trader
  • Initial customer due diligence form - Trust
  • Onboarding form - Body corporate, partnership or unincorporated association
  • Onboarding form - Government body
  • Onboarding form - Individual or sole trader
  • Onboarding form - Trust

Escalation and unusual activity

5

Used when something does not look right, and to record what you did about it.

  • Enhanced CDD form
  • Escalation form
  • Escalations register
  • Unusual activity report information form
  • Unusual activity report review form

Ongoing monitoring

2

Re-checking a customer on a schedule, or when something changes.

  • Periodic review and update form
  • Trigger event review and update form

Personnel forms

5

Who does what, and the due diligence you run on your own staff.

  • AMLCTF roles form
  • Assign responsibilities form
  • Personnel due diligence for AMLCTF compliance officer form
  • Personnel due diligence form
  • Personnel due diligence where the compliance officer and governing body are the same person form

Maintaining the program

10

The annual and periodic checks that show the program is working.

  • Annual report to the governing body form
  • CBM reporting effectiveness check form
  • Client onboarding effectiveness check form
  • Compliance officer and senior manager effectiveness check form
  • Enhanced CDD effectiveness check form
  • Independent evaluation response form
  • Maintain your AMLCTF program form
  • Periodic effectiveness testing summary form
  • SMR effectiveness check form
  • TTR effectiveness check form

Document names are AUSTRAC’s, with the sector prefix and date stamp removed. The groupings are ours: AUSTRAC’s own folder names differ between sectors, so the six above are one vocabulary that holds across all five kits. Check the libraries on austrac.gov.au.

Before the kit

Illustration: an open book of legislation under a magnifying glass
The Act and the Rules decide it — the kit only helps you apply them

A kit is easier once the vocabulary is

AML/CTF has its own vocabulary and its own way of working. The Act and the Rules are the sources that decide anything, but a customise guide is hard to follow if terms like designated service, beneficial owner, enhanced CDD or threshold transaction are new. It is usually quicker to build the understanding first and then open the kit.

A kit also assumes you already know you are a reporting entity and which designated services you provide. If that is still open, start there — the regime regulates services, not professions, and two firms with the same shingle can land on opposite sides of the line.

We are still working on making this material simpler, and on tools to make the kit itself less of a paper exercise. That work is in progress rather than finished. If there is something here you would want explained differently, or a part of the kit you are stuck on, tell us at australia@getpostlabs.io — it genuinely shapes what we build next.

This content is general information only. It is not legal, financial or compliance advice. Organisations should check AUSTRAC guidance, legislation, their own AML/CTF Program and professional advice where needed. The courses and videos linked here are educational material, not legal advice and not a substitute for the Act, the AML/CTF Rules or AUSTRAC’s own guidance. Completing them does not make a business compliant, and nothing on this page is endorsed by or affiliated with AUSTRAC. Whether a starter kit suits your business, and what your program must contain, are judgements for your business to make and to record.

Sources

Every source on this page

This content is general information only. It is not legal, financial or compliance advice. Organisations should check AUSTRAC guidance, legislation, their own AML/CTF Program and professional advice where needed. Published by GetPost Labs Pty Ltd, a technology company building compliance software. Last checked against AUSTRAC’s published guidance on 17 August 2026. If you spot an error, tell us at australia@getpostlabs.io.

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