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Rules Mate

AUSTRAC starter kit: does it fit my firm?

A checklist built from the "who the starter kit is for" criteria in AUSTRAC's five Tranche 2 starter kits.

Short answer: Only if you meet every criterion

AUSTRAC publishes five kits: legal profession, accountant, conveyancer, real estate and jeweller. There is no kit for trust and company service providers. A firm can rely on a kit only if it meets every one of the kit's criteria; if it fails any of them, AUSTRAC says it cannot rely on the starter kit to meet AUSTRAC's expectations.

Criteria in every kit

Answer yes to all of these:

  • No more than 15 personnel
  • Provides only the designated services the kit is written for
  • Customers are mostly Australian-resident individuals
  • No regular high-risk customers
  • No overseas property transactions
  • No fully remote, self-service onboarding
  • Not acquiring another business
  • Not part of a large reporting group or a foreign branch

Extra criteria by kit

KitAdditional criterion
Legal professionPractitioners hold a practising certificate
ConveyancerNon-lawyer conveyancers only; client funds handled only for real estate transactions
Real estateBrokering only; not a property developer
JewellerNo virtual assets; regulated cash accepted from individual customers only

What a kit contains

  • A Customise guide
  • An ML/TF risk assessment (the legal kit has two: other professional services, and conveyancing)
  • A Policy document and a Process document
  • Personnel forms: roles, responsibilities, compliance officer due diligence, a combined compliance officer and governing body form for one-person practices, and general personnel due diligence
  • Client onboarding and initial customer due diligence forms for each customer type, plus a reliance form
  • Escalation forms: unusual activity report, escalation form, enhanced due diligence form, review form and escalations register
  • Maintenance forms: maintain-program form, independent evaluation response, effectiveness checks and an annual report to the governing body

The legal profession kit is version 2, released 10 June 2026. AUSTRAC says that if a business fits the criteria and builds its program from the kit, its engagement will focus on how the business applies the program.

If you fail a criterion

You still need a complete AML/CTF program before providing a designated service. Use the kit as a starting point if it helps, but your ML/TF risk assessment and policies must cover the features that took you outside the kit, for example remote onboarding, overseas property, more than 15 personnel or virtual assets.

Check your AML/CTF programUpload the AML/CTF program you already have and get a gap score against the Tranche 2 requirements of the Act and Rules. Personal information is removed before analysis.Primary actionRun the compliance journeyAnswer a short questionnaire about your business and get the obligations that apply to you, with the reason each one applies.

Questions

Is there an AUSTRAC starter kit for trust and company service providers?
No. AUSTRAC's kits cover legal, accounting, conveyancing, real estate and jewellers only.
What is the personnel limit for the starter kits?
The kits are written for businesses with no more than 15 personnel.

Related

Sources

Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.