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.
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- Static document — your program is a Word doc that quickly becomes outdated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 $31.3 million for companies
- Up to $6.26 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: Get compliant 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? Run a free compliance check — no signup, no credit card, takes 2 minutes. Or view our pricing to start your 14-day free trial.