With AUSTRAC's Tranche 2 reforms now in effect, every accountant, lawyer, conveyancer, real estate agent, and jeweller providing designated services needs an AML/CTF compliance program. The first question most business owners ask: how much is this going to cost me?
Here's an honest breakdown.
Want your own number? Try the AML compliance cost calculator to estimate your annual cost in seconds, based on your client volume and team size.
The Three Main Options
| Approach | Cost | Time to Comply | Ongoing Effort |
|---|---|---|---|
| DIY | $0 (your time) | 4-8 weeks | High |
| Hire a Consultant | $3,000–$10,000+ | 2-6 weeks | Medium |
| Use Compliance Software | $49–$179/month | 1 day–1 week | Low |
Let's break down each one.
Option 1: Do It Yourself ($0 + Your Time)
AUSTRAC has published free program starter kits for each industry. You can download templates and build your AML/CTF program from scratch.
What you'll need to do:
- Read 100+ pages of AUSTRAC guidance
- Write a Part A-F AML/CTF program (30+ pages)
- Create a risk assessment for your business
- Set up CDD procedures and forms
- Build a system for tracking clients, screening, and monitoring
- Create reporting processes for SMRs and TTRs
- Implement staff training
Hidden costs:
- Your time: 40-80+ hours if you've never done compliance before
- Opportunity cost: Time spent on compliance is time not spent on billable work
- Risk of errors: Getting it wrong could mean penalties or AUSTRAC scrutiny
- Ongoing maintenance: You need to review and update the program regularly
Best for: Compliance professionals who already understand AML/CTF frameworks.
Not ideal for: Busy practitioners who need to keep serving clients.
Option 2: Hire a Compliance Consultant ($3,000–$10,000+)
Specialist AML/CTF consultants can build your program for you. Prices vary significantly:
| Service | Typical Cost |
|---|---|
| Initial AML/CTF program setup | $3,000–$5,000 |
| Risk assessment | $1,500–$3,000 |
| Staff training (per session) | $500–$1,500 |
| Annual program review | $1,500–$3,000 |
| Ongoing retainer | $500–$2,000/month |
| Total first year | $5,000–$15,000+ |
Some firms charge per entity type. Others offer packages. Enterprise-grade services like WhiteLight AML charge around $9,895 per 1,000 units for outsourced compliance.
What you get:
- Tailored program written by an expert
- Usually includes initial risk assessment
- May include staff training sessions
- Ongoing support (if on retainer)
Downsides:
- Expensive — especially for solo practitioners
- Static document — your program is a Word doc that quickly becomes outdated
- No ongoing tools — you still need a system to manage clients, screen sanctions, file reports
- Dependency — any changes require billable hours
Best for: Medium-to-large firms with compliance budgets who want a human expert.
Option 3: Compliance Software ($49–$179/month)
SaaS platforms automate program generation, client management, screening, and reporting.
Software Comparison
| Feature | AML Mate | Easy AML | First AML |
|---|---|---|---|
| Monthly price | $49 | $179 | POA (enterprise) |
| Free trial | 14 days | Free until Jul 2026 | No |
| AML/CTF program generator | AI-powered, Part A-F | Template-based | N/A |
| Client KYC/CDD | Built-in + EIV | Built-in | Built-in |
| Sanctions/PEP screening | DFAT + OpenSanctions | Scantek | Biometric KYC |
| SMR/TTR reporting | Guided forms | Basic | N/A |
| Staff training | 5 modules + quizzes | N/A | N/A |
| AI compliance assistant | Yes (AUSTRAC-trained) | No | No |
| Target market | Solo/small firms | Solo/small firms | 400+ individuals/year |
| Annual cost | $588 | $2,148 | $10,000+ |
AML Mate costs 73% less than Easy AML — $588/year vs $2,148/year — while including features like an AI assistant and built-in staff training that competitors don't offer.
What software gives you:
- AML/CTF program generated in minutes (not weeks)
- Dashboard for managing client CDD
- Automatic sanctions and PEP screening
- Guided reporting (SMR, TTR, annual compliance report)
- Audit trail and record keeping
- Updates when regulations change
- Staff training modules
Best for: Solo practitioners and small firms (1-15 people) who want to comply without becoming compliance experts.
The Real Cost of Non-Compliance
Before deciding what to spend on compliance, consider what non-compliance costs:
| Entity | Penalty | Reason |
|---|---|---|
| Westpac | $1.3 billion | 19+ million AML/CTF breaches |
| Commonwealth Bank | $700 million | Systematic failures |
| Crown Resorts | $450 million | Serious non-compliance |
| SkyCity Adelaide | $67 million | Systemic failures |
| Cointree (crypto exchange) | $75,120 | Late SMR submissions |
These aren't just big banks. In 2024 alone, AUSTRAC issued 14 infringement notices to businesses of all sizes. Under the reformed Act, penalties can reach:
- Up to $36.4 million for companies
- Up to $7.28 million for individuals
- Daily penalties for failing to enrol with AUSTRAC
Even a single infringement notice can cost $75,000+. That makes a $49/month software subscription look like very cheap insurance.
What About Free Options?
AUSTRAC's free resources:
- Program starter kits (templates for each industry)
- AML/CTF Essentials webinars (8,000+ attendees)
- Guidance documents and fact sheets
These are excellent starting points, but they're templates — not a complete solution. You still need to:
- Customise templates to your business
- Set up a system to manage ongoing CDD
- Screen clients against sanctions lists
- File reports when required
- Train staff and keep records
AML Mate's free compliance check at amlmate.com.au/check gives you a quick assessment of your obligations — no signup required.
Cost Comparison Summary
For a solo practitioner or small firm (1-5 people):
| Approach | Year 1 Cost | Ongoing Annual | Total 3-Year Cost |
|---|---|---|---|
| DIY | $0 (40-80 hrs time) | 20+ hrs/year | Your time |
| Consultant | $5,000–$10,000 | $3,000–$5,000 | $11,000–$20,000 |
| Easy AML | $2,148 | $2,148 | $6,444 |
| AML Mate | $588 | $588 | $1,764 |
Our Recommendation
For most Tranche 2 businesses — especially solo practitioners and small firms — compliance software is the best value. It gives you:
- Speed: Build your AML/CTF program in hours, not weeks
- Cost: A fraction of consultant fees
- Completeness: Program + CDD + screening + reporting + training in one platform
- Ongoing compliance: Not a static document that gathers dust
The July 2026 deadline has passed. Enrolment is open now. AUSTRAC expects to see genuine effort to comply — having a documented AML/CTF program with active client management demonstrates exactly that.
Ready to see what compliance looks like for your business? Estimate your annual cost with our calculator, run a free compliance check with no signup, or view our pricing to start your 14-day free trial.