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14 min readlex-aml · Platform · Compliance

From Paper to Platform: How lex-aml Turns AUSTRAC's Starter Kits into a Live Compliance System

AUSTRAC published the starter kits. lex-aml digitises them — turning Word documents and PDF checklists into workflows, automated risk scoring, and built-in reporting across 10 modules and a 7-phase compliance lifecycle.

SA
Brisbane, Australia·February 2026·14 min read

The Problem We Solve

AUSTRAC's starter kits are comprehensive. But they are paper documents. A three-person conveyancing practice downloading a 40-page Word document, a 30-page Process Document, and a Risk Assessment template still needs to figure out how to actually run compliance day to day. How do you track which customers have been verified? How do you know when a periodic review is due? How do you file an SMR in the right format? How do you prove to AUSTRAC that you're doing what your program says you're doing?

lex-aml takes AUSTRAC's three-step lifecycle — Customise, Use, Maintain — and turns each step into software. Every form is digitised. Every decision is tracked. Every record is retained. Every deadline is enforced.

1

The Three-Step Lifecycle, Digitised

How lex-aml maps to AUSTRAC's Customise, Use, Maintain framework

01

Customise Your Program

AUSTRAC Paper Approach

AUSTRAC says: Download the starter kit, read the Customise Guide, fill in Word documents, print and file.

lex-aml Digital Approach

lex-aml provides a guided setup wizard. Configure your organisation, designated services, risk appetite, country ratings, and personnel. Complete Personnel Due Diligence (PDD) digitally. Get senior manager approval with a tracked approval workflow. Your Risk Assessment and Policy Document are generated from your configuration — not typed into a blank template.

Platform Features
Organisation profile with ABN, sector, designated services
Risk appetite configuration with sliders and defaults from AUSTRAC
Country risk ratings pre-loaded from FATF and AUSTRAC lists
Personnel management — roles (CP, CO, GB), PDD tracking, training records
Compliance officer appointment with fit-and-proper-person criteria checklist
Senior manager approval workflow with digital signature and date stamp
Version control — every change tracked, every version retained
02

Use Your Program Daily

AUSTRAC Paper Approach

AUSTRAC says: Use your Process Document SOPs to onboard customers, verify identity, run screening, score risk, escalate, and file reports. Keep records.

lex-aml Digital Approach

lex-aml digitises every SOP into a workflow. Onboard a customer and the system walks your staff through the CDD process step by step — collect KYC, verify identity, screen sanctions and PEP lists, assess source of funds, assign a risk rating, and flag anything suspicious. Escalations route to the compliance officer. Reports are generated in AUSTRAC format. Every decision, every check, every document is recorded automatically.

Platform Features
CDD case management — one case per customer per designated service
Identity verification workflow by customer type (individual, body corporate, trust)
Sanctions screening against DFAT consolidated list
PEP screening — domestic and foreign, with family and close associate checks
Adverse media checks with documentation
Source of funds and source of wealth assessment forms
Risk scoring — automated based on your risk assessment configuration
Escalation workflow — high-risk cases routed to CO/GB with approval tracking
SMR, TTR, and cross-border movement report generation
Tipping-off safeguards — restricted visibility on SMR-related cases
Record-keeping — every action timestamped and retained for 7+ years
03

Maintain and Review

AUSTRAC Paper Approach

AUSTRAC says: Review your risk assessment annually. Review your program every 3 years. Conduct effectiveness checks. Provide an annual report to your governing body.

lex-aml Digital Approach

lex-aml tracks review deadlines automatically. When your annual risk assessment review is due, the system prompts your compliance officer. When an independent evaluation is required, it generates the evaluation framework. Program amendments are version-controlled. The annual report to the governing body is compiled from platform data — cases processed, risks identified, reports filed, training completed.

Platform Features
Automated deadline tracking — risk assessment review, program review, training renewals
Independent evaluation framework and checklist
Program amendment workflow with version control and GB approval
Annual report generator — compiles metrics from the platform into a governing body report
Training management — track who has been trained, when, and on what
Audit trail — complete, immutable log of all compliance activity
7-year record retention with search and export
2

Ten Modules

Each maps to AUSTRAC's policy and process documents

lex-aml is structured as 10 modules. Each module maps to a specific section of AUSTRAC's Policy Document or Process Document. Access is role-based: Contact Person (CP) handles day-to-day customer work, Compliance Officer (CO) manages the program and files reports, and the Governing Body (GB) approves the program and high-risk decisions.

Role Definitions
CP
Contact Person
The person who handles day-to-day customer interactions and initial CDD collection. In a small practice, this is often the practitioner themselves.
CO
Compliance Officer
The AML/CTF compliance officer appointed under Rule 5-14. Oversees the program, reviews escalations, files reports, manages ongoing CDD. Must be a fit and proper person.
GB
Governing Body
The senior manager or governing body. Approves the AML/CTF program, approves high-risk business relationships, receives the annual compliance report. Ultimately accountable.
3

Seven-Phase Compliance Lifecycle

One continuous loop — not a one-time exercise

AUSTRAC's Process Document defines a compliance lifecycle that every reporting entity must follow. lex-aml structures this as a 7-phase continuous loop. Every CDD case moves through these phases, and the platform tracks where each case sits at any given time.

01
Setup
Configure organisation, assign roles, appoint CO, complete PDD
02
Onboard
Identify customer type, collect ID documents, obtain consent
03
CDD
Verify identity, screen sanctions and PEP, assess risk, assign rating
04
Escalate
Enhanced CDD, adverse media, source of wealth, SM approval
05
Report
File SMRs, TTRs, cross-border movement reports to AUSTRAC
06
Monitor
Periodic reviews, trigger-event detection, ongoing risk assessment
07
Maintain
Effectiveness checks, annual review, program amendments, annual report
loops back to Monitor

The Dashboard shows a pipeline view of all cases across these 7 phases. At a glance, your compliance officer can see how many cases are in CDD, how many are escalated, how many reports are pending, and how many periodic reviews are due. This is the operational cockpit that the paper-based starter kit cannot provide.

4

Regulatory Alignment

How each obligation maps to the platform

The AML/CTF Act and Rules impose 8 core obligations on every reporting entity. Here is how each maps to a lex-aml module and the specific legislative provision it satisfies.

#ObligationWhat It Requireslex-aml ModuleLegislative Ref
01EnrolWithin 28 days of providing a designated serviceOrganisationAct Part 3A · Rules Part 3
02ProgramRisk-based AML/CTF program in place before providing servicesAML/CTF ProgramAct Part 1A · Rules Part 5
03CDDVerify customer identity before providing a designated serviceCDD CasesAct Part 2 · Rules Part 6
04MonitoringOngoing CDD proportionate to riskOngoing CDDRules 6-37 to 6-39
05ReportingSMRs, TTRs, cross-border movement reportsReportingAct Part 3 · Rules Part 9
06Records7-year retention minimumAll modulesAct Part 10
07OfficerAppoint AML/CTF compliance officerPersonnelAct s26J · Rules 5-14
08TrainingPersonnel trained and competentPersonnelRules 5-10 to 5-12
5

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6

References

Primary sources

  • AUSTRACProgram Starter Kits Link
  • AUSTRACAML/CTF Reform — About the Reforms Link
  • Federal Register of LegislationAML/CTF Rules 2025 — Part 5 (AML/CTF Programs) Link
  • Federal Register of LegislationAML/CTF Act 2006 — Part 1A (AML/CTF Programs) Link

Ready to See It in Action?

lex-aml is currently in early access for Tranche 2 entities. Request access to see how the platform handles your sector's starter kit.

Request Early Access
SA
Sumit Arora
16 February 2026

Disclaimer: 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.