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The AUSTRAC AML/CTF Starter Programs provide a structured pathway to achieving AML/CTF compliance that will significantly reduce the effort and cost of AML/CTF compliance for entities required to meet AML/CTF obligations under Tranche 2.
With the 1 July compliance deadline fast approaching, AUSTRAC has published a series of AML/CTF Starter Programs, which serve as an important piece of the AML/CTF compliance jigsaw for small, low-complexity Tranche 2 entities in the legal, accountancy, real estate, buyer’s agents, conveyancing, and jeweller sectors.
Each Starter Program is split into four components, ML/TF Risk Assessment, AML/CTF Policy, AML/CTF Processes, and a series of Forms to be used to achieve operational compliance within a business.
The AML/CTF Starter Programs provide a structured pathway to AML/CTF compliance that will significantly reduce the effort and cost of AML/CTF compliance.
Contents
However, AML/CTF Starter Programs may require varying degrees of active engagement with the material by Tranche 2 entities, depending on the size and complexity of the business.
What is an AUSTRAC AML/CTF Starter Program?
The AML/CTF Starter Programs for each Tranche 2 sector, accountancy, legal, conveyancing, real estate, professionals and dealers in precious metals and stones, are sector‑specific, practical guidance resources designed to help small, low‑complexity Tranche 2 entities meet their new obligations under Australia’s expanded AML/CTF regime.
In short, the AML/CTF Starter Programs:
aim to reduce cost, complexity and uncertainty for newly regulated Tranche 2 entities
provide a regulator‑endorsed starting point for compliant AML/CTF program
are practical, sector‑specific, risk‑based guidance for entities transitioning into the AML/CTF regime.
The AML/CTF Starter Programs were released on 30 of January 2026 as part of AUSTRAC’s broader Tranche 2 education and reform support program.
The primary aim of the AML/CTF Starter Program is to lower the regulatory and cost burden on newly regulated Tranche 2 entities by providing a credible, regulator‑aligned starting point for AML/CTF compliance by:
helping new Tranche 2 entities develop an AML/CTF program more efficiently
avoiding every small business from having to design an AML/CTF framework on their own
reducing uncertainty and misinterpretation of AML/CTF requirements for professions that have not previously been regulated
supporting timely and consistent compliance ahead of Tranche 2 commencement on 1 July 2026.
The AML/CTF Starter Programs form part of AUSTRAC’s commitment to a risk‑based, proportionate regulatory approach, particularly for entities with limited exposure to complex money laundering or terrorism financing risks, consisting of four sector specific components:
an ML/TF Risk Assessment to support identification and understanding of an entity’s ML/TF risks
an AML/CTF Policy aligned to the AML/CTF Act and Rules
an AML/CTF Process to support implementation of the Policy within the organisation
a set of AML/CTF Forms for use within the organisation, which also supports implementation of the AML/CTF Policy and Process , as well as ongoing AML/CTF compliance by the organisation.
The ML/TF Risk Assessment component of the AML/CTF Starter Program provides a pre‑populated, sector‑specific ML/TF risk assessment that reflects the typical services, customers, delivery channels and geographic exposures of businesses within that profession, rather than requiring each entity to build a risk assessment from first principles.
The risk assessment walks entities through common inherent risks relevant to their sector. For example, client types, transaction types, use of intermediaries and cash exposure.
While the risk assessment reflects what AUSTRAC considers a typical risk profile, it is expressly intended to be reviewed, tailored and approved by the entity to account for its own circumstances.
In this way, the risk assessment acts as both a baseline compliance document and an educational tool that significantly reduces the time, cost and uncertainty associated with developing an initial risk assessment.
The AML/CTF Policy component of the AML/CTF Starter Program is designed to operationalise the risk assessment by setting out clear, practical controls for managing identified money laundering and terrorism financing (ML/TF) risks, rather than leaving entities to draft policies from scratch or interpret legislative language on their own.
The policies are aligned with the AML/CTF Act and the AML/CTF Rules but written in plain English and tailored to typical services and workflows within each Tranche 2 profession.
The AML/CTF Policy content reflects a baseline, regulator‑informed position. AUSTRAC is explicit that, unless the Tranche 2 entity meets the small business criteria, these policies are intended to be adapted and approved by each entity to suit its specific operations and ML/TF risk profile.
The AML/CTF Forms component of the AML/CTF Starter Program provides a set of standardised, sector‑appropriate templates and forms that support the practical execution of AML/CTF obligations.
These forms are designed to help entities consistently capture, document and retain key AML/CTF information required under the AML/CTF Act and AML/CTF Rules, without needing to design their own documentation.
The forms align with common regulatory requirements, such as customer due diligence records, risk assessment confirmations, internal reporting and escalation records, and staff acknowledgements of AML/CTF responsibilities.
The focus of the AML/CTF Forms is to ensure that entities can readily demonstrate that required checks have been performed, decisions have been made on a risk basis, and obligations have been consistently complied with.
The AML/CTF Forms helps embed AML/CTF compliance into everyday workflows while also supporting audit readiness, regulatory engagement and staff training.
The AML/CTF Process component of each AML/CTF Starter Program translates the AML/CTF Policy into clear, step‑by‑step instructions that explain how staff are expected to carry out AML/CTF controls in practice.
These process describe the operational steps required to apply customer due diligence, identify and respond to suspicious matters, keep required records, and escalate issues internally.
By setting out practical workflows that reflect typical service delivery in each sector, the process helps ensure that AML/CTF obligations are embedded into day‑to‑day business activities, rather than existing only as high‑level policy statements.
The AML/CTF process is designed as baseline operational guidance connecting directly to the ML/TF Risk Assessment and AML/CTF Policy, demonstrating when controls must be applied, who is responsible, and what actions must be taken in different scenarios.
AUSTRAC makes it clear that these process must be tailored and approved by each entity to reflect its own systems, size and risk exposure, but when adapted appropriately, they provide a practical and defensible framework for consistent AML/CTF compliance and staff training.
AUSTRAC has been explicit that the AML/CTF Starter Programs are not one‑size‑fits‑all, but rather scalable tools that sit within a proportionate compliance model.
AUSTRAC’s AML/CTF Starter Programs are designed to be applied proportionately, consistent with Australia’s risk‑based AML/CTF regime, which allows entities to tailor their compliance arrangements to their nature, size and complexity – and ML/TF risks faced.
For small, low‑complexity Tranche 2 entities, the AML/CTF Starter Programs are intended to function as a near‑complete foundational AML/CTF framework, covering risk assessment, policies, process and supporting forms aligned with typical sector risks, significantly reducing the need for further bespoke design work.
As the size or complexity of the entity increases, the way the AML/CTF Starter Programs are used shifts. Medium or more complex entities, such as those operating across multiple locations, or dealing with more complex customer structures, are expected to use the AML/CTF Starter Programs as a reference point rather than a complete solution.
In these cases, the AML/CTF Starter Programs help establish baseline expectations, but entities must extend or modify the risk assessment, policies and process to reflect their actual risk exposure.
We’re here to help
If you would like more information on how to use, adapt, adopt and implement the AML/CTF Starter Programs, Grant Thornton is uniquely placed, as we were engaged by AUSTRAC to support the development of the AML/CTF Starter Programs.
We worked closely with industry stakeholders to develop, draft, and refine the materials now published by AUSTRAC.
Learn more about how our Anti-Money Laundering reforms services can help you
As Australia prepares for the landmark Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms – set to take effect in the coming months – businesses across sectors face a pivotal moment not just to comply with how to manage financial crime risk, but to transform themselves for the better. The real challenge lies in building a culture that embeds AML obligations into the DNA of an organisation.
How leadership teams can implement effective ML/TF risk management, ongoing AML/CTF compliance, and the successful definition and embedding of an organisation's AML/CTF compliance culture.
Grant Thornton is a leading specialist in AML/CTF risk management and can assist businesses by providing tailored AML/CTF risk management and compliance services
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