AUSTRAC’s free Accounting Program Starter Kit is a helpful starting point – but it is not suitable for every firm. AUSTRAC has defined eight specific criteria that must all be
met before a firm can rely on the kit. If your firm fails even one, the kit is not sufficient on its own and you must document additional controls or build a tailored program.

Here are the eight criteria. Answer each one honestly.

Question 1 – Do you have 15 or fewer total staff?
This includes accountants, bookkeepers, admin, and support staff – every person on the practice payroll. If you have more than 15 staff the kit is not suitable for your firm.

Question 2 – Are your designated services limited to professional services only?
No real estate transaction assistance, no dealing in precious metals, no remittance. If your firm provides any service outside standard accounting professional services the kit
does not cover you.

Question 3 – Are most of your clients individual Australian residents?
Body corporates, trusts, and foreign residents should be the exception not the norm. If complex entities or foreign clients make up a significant portion of your client base the
kit is not sufficient.

Question 4 – Do you have no regular dealings with high-risk clients?
PEPs, cash-intensive businesses, complex multi-layered structures, and high-net-worth clients with opaque source of wealth all disqualify the kit if they are a regular part of
your practice.

Question 5 – Do you have no involvement in overseas property transactions?
Buying, selling, or transferring property located outside Australia – even occasionally – disqualifies the kit entirely.

Question 6 – Do you have no fully remote self-service onboarding?
Clients must interact with firm personnel at some point. If your firm uses automated end-to-end onboarding without any human contact the kit does not apply.

Question 7 – Is your firm not acquiring another practice or transferring clients in?
M&A activity within the practice itself requires separate transition procedures. The kit does not cover these scenarios.

Question 8 – Is your firm not part of a large reporting group, foreign branch, or subsidiary?
The kit applies to standalone firms with simple structures only. Group-wide AML/CTF arrangements require a different framework entirely.

 

What Your Score Means

0 No’s – Kit is suitable
You can customise and adopt the Starter Kit. Pair it with a SaaS execution layer for verification, screening, audit trail, and SMR workflow to ensure you have operational
evidence not just documentation.

1-2 No’s – Kit needs adaptation
Use the kit as a base but your firm must document why it remains suitable and add specific controls for each gap area. This carries higher audit risk if left undocumented.

3 or more No’s – Tailored program required
AUSTRAC has effectively written your firm out of the kit. A tailored AML/CTF Program is required – built on the kit’s framework but extended to match your firm’s actual risk
profile.

Why This Matters Under Section 167 and Section 172A

Under amended enforcement powers AUSTRAC can issue a Section 167 notice demanding records from anyone with relevant information. Under Section 172A AUSTRAC can
compel your AML Compliance Officer to attend a compulsory examination under oath.

 

If your firm relies on the Starter Kit but does not meet all eight suitability criteria, the burden falls on your firm to justify why the kit was appropriate. Documenting that
justification – and the controls added to fill the gaps – is itself a significant piece of work.

Most SME accounting firms have at least one or two criteria they cannot honestly tick. That is not a problem – it just means the kit alone is not enough and additional
controls are needed.

ComplyHub is specifically designed for firms with 1-2 suitability fails. The platform extends the Starter Kit framework with the operational controls needed to fill those gaps
– producing a stronger audit posture than either DIY or bespoke alternatives at a fraction of the cost.

Ready to find out which path is right for your firm? Book a 30-minute discovery call with ComplyHub today.