You enrolled in July. Now you have to write the program, and there is a free, sector-specific starter kit sitting on AUSTRAC's website with your profession's name on it. Downloading it is the obvious first move, and it is the right one.
Before you build on it, read the page it sits behind. There is a list on it, and the sentence under the list is the one that matters.
"If your practice meets all these characteristics"
That is AUSTRAC's own wording (AUSTRAC, accounting starter kit, getting started, updated 10 July 2026). Not most of them. All of them.
Each sector kit carries its own list of nine or ten characteristics, and they read like a description of a small, simple, local practice. Which is exactly what they are: the kits were built for that firm, and AUSTRAC is being upfront that they were not built for anyone else.
If you do not meet all of them, here is what the same page says happens:
You cannot rely on the starter kit to meet AUSTRAC's regulatory expectations of an appropriate AML/CTF program for your practice.
And:
Large practices are highly likely to face different and more complex ML/TF risks than those addressed by the starter kit. These will generally require stronger or additional controls.
The kit does not stop working. It stops being a defence.
The condition everyone checks first
Fifteen or fewer personnel. It appears in every sector kit, worded almost identically, and with the same clarification each time:
This includes all your personnel such as administrative staff as well as accountants.
Administrative staff count. So do the people who never touch a client file. A twelve-accountant practice with five admin and two receptionists is a seventeen-person practice for this purpose, and it is out.
That catches more firms than you would think, because most people hear "fifteen staff" and count fee earners.
The conditions that actually catch people
Headcount is the one firms check. These are the ones they fail without noticing.
You may only provide the one designated service the kit was written for. The real estate kit assumes brokering purchases, sales and transfers and nothing else. The jeweller kit assumes cash or linked transactions of $10,000 or more and nothing else. An agency that also does something captured, or a firm that straddles two kits, is outside both.
You must not be acquiring another practice, or taking on clients transferred from one. Every sector list carries this, and it is the quietest disqualifier of the lot. If you bought a book of clients this year, you are outside the kit, and AUSTRAC points you at the separate transitioning-existing-customers procedures instead.
No overseas property. Accountants and lawyers are out if they assist with the purchase, transfer or sale of overseas property. Real estate agencies are out if they broker it.
No selling property you own. Property developers are named explicitly in both the real estate and legal lists.
Jewellers: no virtual asset payments. Accept crypto for a piece and the kit no longer covers you.
No fully remote self-service. If a customer can obtain the designated service without interacting with your people at all, you are outside every one of the kits.
Not part of a large reporting group, foreign branch or subsidiary. Standard, and it is on every list.
Sector by sector
| Accountants | Legal | Real estate | Jewellers | |
|---|---|---|---|---|
| Personnel (incl. admin) | 15 or fewer | 15 or fewer | 15 or fewer | 15 or fewer |
| Designated services | professional services only | professional services only | brokering only | cash/linked $10k+ only |
| Overseas property | must not assist | must not assist | must not broker | n/a |
| Sells property it owns | n/a | must not | must not | n/a |
| Virtual asset payments | n/a | n/a | n/a | must not accept |
| Acquiring a practice or taking transferred clients | must not | must not | must not | must not |
| Remote self-service | must not offer | must not offer | must not offer | must not offer |
| High-risk customers | not regularly | not regularly | not regularly | not regularly |
Sources: accounting and jeweller kits updated 10 July 2026, real estate 10 July 2026, legal profession 12 June 2026.
One note for conveyancers: the legal kit applies where personnel providing designated services operate under a legal practising certificate. A conveyancing practice that does not has its own kit, and AUSTRAC's legal page points there directly.
Failing one of these is not a disaster
It is a scoping change, and AUSTRAC says as much:
You must assess whether the starter kit is appropriate for your practice and identify any changes you need to make. You can consider whether parts of the starter kit may be adapted when developing your own AML/CTF program.
So the kit goes from adopt to adapt. You use its structure, its language and its sense of what AUSTRAC expects to see, and you build the parts it does not cover because your practice is bigger, or does more than one thing, or just bought a client book.
What you cannot do is fill in the blanks on a document written for a different firm and treat that as a program. The obligation is that your program reflects the size, nature and complexity of your business and the risks it faces. A kit written for a nine-person suburban practice cannot make that statement true for a thirty-person firm across three offices.
The awkward middle
There is a group this hits hardest, and it is not the big firms. Large practices have compliance people who read the eligibility list.
It is the firm at eighteen or twenty-two people. Too big for the kit, too small to have anyone whose job is compliance, and with a managing partner who downloaded the free templates in good faith and now has a document that describes a business other than theirs. That firm's program looks finished and is not, and nothing will tell them until an examiner asks how the risk assessment was tailored.
If you are in that group, the useful move is not to buy something. It is to spend twenty minutes going down the list for your sector and writing down which conditions you fail and why. That note is worth having whatever you build next, because it is the beginning of the argument for why your program looks the way it does.
Where AML Mate fits
The kits assume a shape. Our program generator asks what shape you actually are: which designated services you provide, how many people, what your client mix looks like, and it builds Parts A to F from that rather than from a template you edit down. The risk assessment is generated from your answers for the same reason.
Being straight about the overlap: for a practice that genuinely meets every characteristic on its sector list, AUSTRAC's kit is free and it is enough to start with. Our gap analysis of what the kits cover and miss goes through where they stop. This post is about the question that comes before that one.
The short version
- Every sector kit has an eligibility list, and you must meet all of it.
- Fifteen or fewer personnel, including administrative staff, not just fee earners.
- Only the one designated service the kit was written for.
- Acquiring a practice or taking on transferred clients puts you outside every kit.
- If you fail one, adapt the kit rather than adopt it, and write down which condition you failed.
- Your program must reflect the size, nature and complexity of your own business. A template cannot do that for you.
The kits are a genuinely generous piece of work by a regulator that did not have to do it. They are also, on their own page, honest about who they are for. That page is worth the five minutes before you build a year of compliance on top of it.
This article is general information, not legal advice. For advice specific to your circumstances, consult a qualified AML/CTF professional.