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Overall they rate well. Here is what they got right and where they fell short. Last reviewed 5 August 2026 · Reviewed by [Jamie Nuich](/attorney/jamie-nuich), Legal Practitioner Director · Published 25 February 2026 ## Key Takeaways - Of 45 audit items assessed against the AML/CTF Act 2006 (Cth) and AML/CTF Rules 2025, the AUSTRAC starter kits fully addressed 25, partially addressed 12 and missed 8 entirely. - The Legal Professionals kit omits the mandatory Legal Professional Privilege (LPP) notification form required under s 242 of the AML/CTF Act, a notable gap for a kit specifically designed for lawyers. - The kits' jurisdiction risk methodology uses a three-step process (Basel AML Index, FATF/DFAT override, fallback) but provides vague guidance for countries not covered by any of these sources. - Escalation procedures in the kits go beyond what the AML/CTF Rules 2025 require, adding administrative overhead not prescribed by Rule 5-7 for smaller practices. - The kits are static Word documents with no digital workflow, automation or version control, making implementation and audit trail management a significant burden for reporting entities starting from scratch. ![The cover of an AUSTRAC free AML/CTF program starter kit, reviewed against the mandatory requirements](/images/articles/austrac-starter-kit-cover.jpg) In This Article 1. [1. What Is the AUSTRAC Starter Kit?](#what-is-the-austrac-starter-kit) 2. [2. The Common Gaps We See in Compliance Reviews](#the-common-gaps-we-see-in-compliance-reviews) 3. [3. Important Context](#important-context) 4. [4. The Assessment Framework](#the-assessment-framework) 5. [5. Summary](#summary) 6. [6. Notable Concerns](#notable-concerns) 7. [7. Full Assessment](#full-assessment) 8. [8. Sector-Specific Issues](#sector-specific-issues) 9. [9. The Manual Setup Problem](#the-manual-setup-problem) 10. [10. What the Kits Do Well](#what-the-kits-do-well) 11. [11. Conclusion](#conclusion) AUSTRAC released free starter program kits for five Tranche 2 sectors in January 2026. We ran them against the mandatory requirements in the AML/CTF Act 2006 (future law compilation) (s 26C, s 26F) and AML/CTF Rules 2025. Here is our assessment. **Overall, the kits rate well** - a solid foundation with notable gaps in reporting groups, CDD sharing and outsourcing, jurisdictional coverage, implementation burden and legislative referencing. > AUSTRAC CEO Brendan Thomas said the release of the kits marked a key point in the implementation of the anti-money laundering reforms. "AUSTRAC's program starter kits mark the first time that an anti-money laundering regulator anywhere in the world has provided this level of practical support to business". ## What Is the AUSTRAC Starter Kit? The AUSTRAC starter kits are free packs of AML/CTF program templates published by AUSTRAC in January 2026 for the new Tranche 2 sectors: legal professionals, accountants, real estate professionals, trust and company service providers and dealers in precious metals and stones. Each kit contains editable Word documents - an ML/TF risk assessment template, AML/CTF policy documents, customer due diligence forms, registers and related records - intended to give a small reporting entity the skeleton of the program it must have in place under the reformed AML/CTF Act before providing designated services. Three things to understand before you rely on one. First, the kits are aimed at entities with 15 or fewer personnel; larger or more complex businesses will outgrow them immediately. Second, they are templates, not a compliance program: an unedited kit sitting in a folder satisfies nothing, because the Act requires a risk assessment and policies that reflect _your_ services, customers, delivery channels and jurisdictions. Third, downloading the kit does not register you - AUSTRAC enrolment (and registration where applicable) is a separate obligation with its own deadlines. ## The Common Gaps We See in Compliance Reviews When we review AML/CTF programs built on the starter kits (or on any template), the same gaps come up repeatedly: - **The customisation gap.** The template's example risk ratings are left untouched, so the "risk assessment" describes a hypothetical business rather than the actual one. This is the single most common finding. - **Reporting groups, CDD sharing and outsourcing.** The kits barely address multi-entity structures - firms with service trusts, related entities or outsourced back offices need policies the kits do not provide. - **Jurisdiction risk with no methodology.** Customers or funds touching countries outside the Basel/FATF/DFAT lists get no documented risk rating at all. - **Privilege handling for lawyers.** The Legal Professionals kit omits the LPP notification form required under s 242, and firms rarely add a documented privilege-review step to their reporting workflow. - **No evidence trail.** Static Word documents with no version control mean the entity cannot show AUSTRAC when the program was adopted, reviewed or updated - which matters, because the independent evaluation requirement assumes an auditable trail. - **Governance on paper only.** The policies name a compliance officer and governing-body oversight, but there are no board minutes, training records or annual reports actually evidencing it. If any of those sound familiar, our [AML/CTF compliance practice](/practice/anti-money-laundering) runs fixed-scope Tranche 2 readiness engagements: we customise the risk assessment and policies to your practice, close the gaps above and leave you with the evidence trail an AUSTRAC review expects. The full item-by-item assessment below shows exactly what the kits do and do not cover. ## Important Context The AUSTRAC starter kits are designed for smaller reporting entities with **15 or fewer personnel**. They are a starting point, not a finished compliance program. AUSTRAC states they must be customised for your circumstances. This assessment is not a criticism of AUSTRAC. It is a factual review of what is and is not covered, measured against the statutory requirements in the Act and Rules. ## The Assessment Framework We assessed each kit against nine categories derived directly from the AML/CTF Act and AML/CTF Rules 2025. These are not optional extras. They are mandatory requirements for reporting entities: - **1\. ML/TF Risk Assessment** (s 26C) - **2\. AML/CTF Policies** (s 26F) - **3\. Governance** (s 26F(4)) - **4\. Personnel & Training** (Rule 5-8, 5-9) - **5\. Independent Evaluation** (Rule 5-10) - **6\. Customer Due Diligence** (Part 2 Act) - **7\. Reporting** (Part 3 Act) - **8\. Record Keeping** (Part 10 Act) - **9\. Reporting Groups** (s 26F(5)-(6)) ## Summary Across 45 audit items assessed against the Act and Rules: - **25 Included** - fully addressed in the kits - **12 Partial** - referenced but incomplete or lacking process detail - **8 Missing** - not addressed at all ## Notable Concerns Beyond the category-by-category assessment below, we identified several broader concerns with the kits. ### Jurisdiction Risk Methodology - Vague Fallback The kits use a three-step jurisdiction risk methodology: Step 1 uses the Basel AML Index as a baseline rating, Step 2 checks FATF high-risk lists and DFAT sanctions (overriding the Basel rating if a country appears on either list) and Step 3 provides a fallback for countries not covered by any of these sources. This means sanctioned countries like Russia are properly caught by the DFAT override even though Basel does not cover them. However, the fallback for countries that do not appear on Basel, FATF or DFAT is vague, directing users only to "consider the materials underpinning the Basel Index methodology" without further detail on how to assign a risk rating. This leaves a gap for less well-known jurisdictions where none of the three sources provide coverage. ### Escalation Procedures - Overreach? The kits include detailed escalation forms and registers. The AML/CTF Act and Rules 2025 do not use the word "escalation". Rule 5-7 requires AML/CTF compliance officers to report to the governing body at least annually on compliance and risk management, but this obligation does not apply where the compliance officer and the governing body are the same person (Rule 5-7(3)). The kit escalation procedures - including formal escalation registers and mandatory second-reviewer sign-offs - go well beyond this reporting requirement and add administrative overhead that is not prescribed by the legislation, particularly for smaller practices. ### Missing LPP Form for Lawyers The Legal Professionals kit does not include the Legal Professional Privilege (LPP) notification form required under s 242 of the Act. This is a mandatory reporting document for lawyers claiming privilege over information that would otherwise be reportable. Its absence from a kit specifically designed for legal professionals is a notable oversight. Privilege and tipping-off sit at the heart of the [ASCR rule 8 and rule 12 obligations](/article/ascr-rule-8-rule-12-aml-ctf-open-submission) we examined in our open submission to the Law Council, including the conflicts duty the reforms leave unresolved. ### Ease of Implementation The kits are static Word documents requiring manual customisation, filing and tracking. There is no digital workflow, no automation and no version control. For a reporting entity starting from scratch, the implementation burden is significant. Every document must be individually downloaded, edited, saved and stored, with no mechanism to track completion, flag overdue reviews or maintain an audit trail of changes. ### Legislative References The kits do not cite specific provisions of the AML/CTF Act 2006 or AML/CTF Rules 2025 against each requirement or form. Without section references, a reporting entity cannot easily verify what statutory obligation a particular document is intended to satisfy or confirm whether their customised version still meets the legislative standard. This makes independent verification and audit preparation considerably harder. ## Full Assessment The tables below show each requirement we assessed, whether it is included in the AUSTRAC kits and what is missing or incomplete. ### 1\. ML/TF Risk Assessment Requirement Reference Status Notes Identify and assess ML/TF/PF risks s 26C(1) Included Risk assessment template provided across all kits. Consider designated services provided s 26C(3)(a) Included Designated services considered in risk assessment template. Consider types of customers s 26C(3)(b) Included Customer types addressed in risk assessment template. Consider methods of service delivery s 26C(3)(c) Included Delivery channels considered in risk assessment template. Consider foreign jurisdictions dealt with s 26C(3)(d) Partial Foreign jurisdictions addressed using a three-step methodology (Basel AML Index rating, then FATF/DFAT override). Sanctioned countries like Russia are caught by the DFAT override. However, the fallback for countries not covered by Basel, FATF or DFAT is vague, directing users only to "consider the materials underpinning the Basel Index methodology" without further detail. Consider any other information from AUSTRAC s 26C(3)(e) Included AUSTRAC information considered in risk assessment template. Review triggers for risk assessment updates s 26D Partial Template exists but no automated scheduling, reminders or version tracking for periodic reviews. ### 2\. AML/CTF Policies Requirement Reference Status Notes Manage and mitigate ML/TF risks s 26F(1)(a) Included Core policy document addresses risk management and mitigation. Ensure compliance with AML/CTF Act obligations s 26F(1)(b) Included Compliance procedures included in policy document. Appropriate to nature, size and complexity of business s 26F(1)(c) Included Kits designed for smaller entities (15 or fewer staff). Acknowledged as starting point. Identify significant changes requiring program update s 26F(3)(a) Included Change identification addressed in policy document. Review and update policies periodically s 26F(3)(c)-(d) Included Review and update obligations referenced in policy. Targeted financial sanctions screening Rule 5-3 Partial Policy references targeted financial sanctions. No screening tools, lists or defined process. Tipping-off prevention procedures Rule 5-13 Partial Mentioned in policy text but no standalone tipping-off prevention procedures or staff protocols. Guardrail / decline policies for out-of-scope services Best practice Missing No procedures for identifying or declining services that fall outside designated service triggers. ### 3\. Governance Requirement Reference Status Notes Governing body oversight of AML/CTF program s 26H, Rule 5-6 Partial Sole practitioner scenarios covered. No board notification or governance process for larger firms. Designate AML/CTF compliance officer s 26F(4)(b) Included Compliance officer designation form included. Designate senior manager s 26F(4)(c) Included Senior manager designation form included. Notify AUSTRAC of compliance officer appointment s 26M Included Notification obligation referenced with instructions. Senior manager approval of AML/CTF program s 26P, Rule 5-5 Included Approval process and form included. ### 4\. Personnel & Training Requirement Reference Status Notes Personnel due diligence Rule 5-8 Included Personnel DD forms included, covering sole practitioner scenarios. Compliance officer fit and proper assessment Rule 5-14 Included Fit and proper assessment addressed in personnel forms. AML/CTF training program Rule 5-9 Partial Policy mentions training obligation. No training content, modules or materials provided. Training register and completion tracking Rule 5-9 Missing No training register, completion tracking or certificate generation. ### 5\. Independent Evaluation Requirement Reference Status Notes Conduct independent review of AML/CTF program Rule 5-10 Partial Response form exists for evaluation findings. No framework for conducting the evaluation itself. Update program on adverse findings Rule 5-4 Included Process for updating program based on adverse findings is addressed. ### 6\. Customer Due Diligence Requirement Reference Status Notes Initial CDD and KYC collection s 28, Rule 5-2 Included Good coverage: individual, body corporate, trust, government entity, foreign company. Beneficial ownership identification s 28(2)(d) Included Beneficial ownership addressed in CDD forms for relevant entity types. PEPs and sanctions screening s 28(2)(e) Partial Policy references PEPs and sanctions. No screening tools, lists or defined screening process. Ongoing CDD and periodic reviews s 30 Partial Review form exists. No automated scheduling, reminders or risk-based review frequency. Enhanced CDD (EDD) procedures s 32 Included EDD procedures and forms included. Simplified CDD provisions s 31 Included Simplified CDD addressed for low-risk scenarios. Reliance on third parties for CDD s 37-38 Partial Policy references third-party reliance. No reliance agreement template or due diligence process. ### 7\. Reporting Requirement Reference Status Notes Suspicious matter reports (SMR) procedures s 41, Rule 5-11 Included SMR process and effectiveness testing forms included. Threshold transaction reports (TTR) procedures s 43 Partial TTR forms included for all sectors. Relevance questionable for sectors where $10k+ cash is rare. International value transfer services (IVTS) s 46 Included Default position addressed: most Tranche 2 entities do not offer international value transfers. Compliance reports to AUSTRAC s 47 Included Compliance reporting obligations referenced. LPP notification form (Legal kit only) s 242 Missing Not included in the Legal Professionals kit despite being a mandatory form for lawyers claiming privilege. Tipping-off safeguards Rule 5-13 Partial Referenced in policy. No standalone procedures or staff protocols for preventing tipping-off. ### 8\. Record Keeping Requirement Reference Status Notes Record retention for 7 years s 111, s 116 Included 7-year retention period referenced in policy documentation. Compliance calendar and periodic review reminders Best practice Missing No compliance calendar, automated reminders or scheduling for periodic obligations. ### 9\. Reporting Groups Requirement Reference Status Notes Reporting group agreement s 26F(5)-(6) Missing Completely absent. No reporting group agreement or lead entity designation. Information sharing arrangement s 26F(5)-(6) Missing No information sharing arrangement between group members. Data privacy policy for shared CDD s 26F(5)-(6) Missing No data privacy or protection protocols for inter-entity CDD sharing. CDD sharing arrangement s 26F(5)-(6) Missing No CDD sharing arrangement or member entity addendum. ## Sector-Specific Issues Beyond the general assessment above, each sector kit has unique issues worth noting. ### Conveyancing - References Table 5 (Real Estate) when conveyancers fall under Table 6 (Professional Services). - Missing Item 3: holding or managing client funds via trust accounts, which is a routine conveyancing activity. - Missing Item 6: trusts, which conveyancers regularly encounter in property transactions. ### Legal Professionals - Missing the LPP notification form (s 242), a mandatory reporting document for lawyers claiming privilege. - Limited coverage of Table 6 Items 4 (company formation), 5 (shelf companies), 7 (nominee director), 8 (nominee shareholder) and 9 (registered office). ### Precious Product Dealers - Kit focused narrowly on jewellers. Does not address other businesses in the precious products sector such as opal dealers, bullion dealers, pawnbrokers, cash converters or scrap metal dealers. - No coverage of the broader "precious products" definition under s 5A(6), which captures any item made from, containing or having precious metals or stones attached. ### Real Estate Agents - No coverage of property developers, who have separate obligations. - TTR effectiveness testing included despite cash transactions being rare in real estate. ### Accounting Professionals - TTR effectiveness testing included, though most accounting practices rarely handle $10,000+ in physical currency. - Limited coverage of designated service triggers beyond basic Table 6 Item 1. ## The Manual Setup Problem Even where the kits do cover a requirement, every document is a static Word file. That means: - Every form must be manually customised, saved, filed and tracked - No version control or document audit trail - No automated reminders for periodic reviews or training renewals - Designed for businesses with fewer than 15 staff - Ongoing maintenance burden: estimated 100+ hours per year for manual compliance management ## What the Kits Do Well To be fair, the AUSTRAC starter kits provide a legitimate free starting point. Several areas are well covered: - Good CDD form coverage across entity types (individual, body corporate, trust, government) - Effectiveness testing forms are comprehensive - Personnel due diligence forms cover sole practitioner scenarios - Getting started guides are helpful for orientation ## Conclusion The kits are a starting point, not a complete AML/CTF program. They must be reviewed and customised for your specific circumstances and designated services. 8 mandatory requirements from the Act and Rules are not addressed at all. A further 12 are only partially covered. Businesses with reporting groups, international dealings or higher-risk profiles will need additional documentation beyond what the kits provide. If you are a Tranche 2 reporting entity preparing for your AML/CTF obligations, we recommend using the free AUSTRAC kits as a reference point, but engaging professional advice to ensure your program meets the full requirements of the Act and Rules. Our AML/CTF practice can assist with program development, gap analysis and independent evaluations. The AUSTRAC free starter kits can be downloaded from [AUSTRAC's website](https://www.austrac.gov.au/business/tranche-2-reforms/aml-ctf-starter-program-kits). ## Update log - August 2026Added a plain-English explanation of what the AUSTRAC starter kits are and a summary of the most common gaps we see in compliance reviews. ![Jamie Nuich, Legal Practitioner Director at Astris Law](/images/jamie-nuich-portrait.jpg) ### [Jamie Nuich](/attorney/jamie-nuich) Legal Practitioner Director - Admitted as a Solicitor of the Supreme Court of Queensland - Admitted as a Solicitor of the High Court of Australia - 15+ years advising directors on commercial law, litigation, regulatory investigations and workplace matters Jamie is the founder and Legal Practitioner Director of Astris Law. She has acted first-hand for directors in urgent injunction applications, shareholder disputes, ASIC prosecutions and regulator-led investigations across Federal and State jurisdictions. She is a solicitor advocate who runs her own applications and trials where appropriate, so clients keep continuity from first advice through to hearing. 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