Do customers need to complete the AUSTRAC Starter Kit separately from the easyAML Program?
No, the Starter Kits are manual templates that the easyAML-generated Program replaces; they are a fallback for businesses without a platform, not a separate regulatory requirement.
AUSTRAC's free Starter Kits are manual templates the firm fills out by hand to produce a basic Risk Assessment and AML/CTF Program. They're a fallback for businesses that haven't chosen a platform - they're not a separate regulatory requirement.
The easyAML-generated Program replaces the Starter Kit equivalent and covers the same ground in more detail:
- AUSTRAC Starter Kit: Manual ML/TF Risk Assessment template
easyAML equivalent: Auto-generated from your Risk Assessment answers - AUSTRAC Starter Kit: Manual AML/CTF Program template
easyAML equivalent: Tailored Program generated from your Risk Assessment, sector and structure - AUSTRAC Starter Kit: Sample policies and procedures
easyAML equivalent: Built into the Program, kept current with regulatory updates - AUSTRAC Starter Kit: Manual training tracking spreadsheet
easyAML equivalent: In-platform training with role-based modules, certificates, audit trail - AUSTRAC Starter Kit: Manual record keeping
easyAML equivalent: Secure 7-year storage on AWS Sydney, read-only auditor access
A firm using easyAML doesn't need to fill out the Starter Kit. The Starter Kit becomes useful only if you want a paper copy of the underlying framework for reference..
The Starter Kit approach is also significantly more time-intensive - easyAML estimates that manual management consumes on average ~10-20 hours per month for a sole trader. The easyAML alternative is the same outcome with substantially less ongoing effort. See AUSTRAC's AML/CTF Program reform materials.