Deplexify.
AML/CTF Program — Australia

You enrolled by the deadline.
Is your program written?

Enrolment was a form. The AML/CTF program is the actual obligation — an ML/TF risk assessment and the policies built on it, documented in writing and approved by a senior manager. It was due before you provided a designated service. Thousands of firms enrolled by 29 July and stopped there. We build the rest, from your answers, in about twenty minutes of your time.

AML solutions developed and led by a Chartered Accountant with 20+ years of experience across public practice, business operations, audit, and government sectors.

Start now — 20 minutes →See a full sample packAsk a question first
Every risk rating shows which of your answers produced it.

AUD $595 for the Program Pack, self-serve and delivered within one working day. AUD $995 done-with-you, reviewed and finalised in a working session. Launch pricing, and no GST — we're not GST-registered.

AUD $595
Flat — self-serve Program Pack
1 day
From your answers to your documents
30 Sep 2027
Your first annual compliance report is due
What you actually owe

Two documents, and neither is optional.

An AML/CTF program is an ML/TF risk assessment plus the AML/CTF policies that manage the risks it finds. Not one or the other, and not a policy document floating free of any assessment — the policies have to be built on the assessment, which is why a set of policies bought off the shelf has nothing holding it up.

It must be in place before you provide a designated service, documented in writing, approved by a senior manager, and complied with. You also need a compliance officer at management level, notified to AUSTRAC — two different clocks, and most firms have only heard of one.

If a template you've been handed talks about a "Part A" and a "Part B", it predates the reforms. That structure is gone, and independent evaluations now cover the whole program.

Who this is for

Regulated since 1 July 2026.

→Real estate agencies and buyer's agents
→Property developers selling their own stock
→Lawyers
→Conveyancers
→Accountants
→Trust & company service providers
→Jewellers and jewellery retailers taking A$10,000+ in cash
→Bullion dealers
→Dealers in precious metals and stones

Not certain whether your services are captured? Say so on the form. Which of your services are designated services is the first real question, and getting it wrong in either direction is expensive. We'll tell you straight, and we won't invoice you for work you don't have to do.

How many firms this applies to

AUSTRAC published these enrolment counts six days before the deadline. Every one of these businesses now owes a written program:

16,210
Real estate
11,400
Accounting & professional services
6,030
Lawyer
1,550
Conveyancer
220
Jewellers / precious metals

Enrolment applications received, per AUSTRAC, 23 July 2026. Enrolling was the visible deadline; writing the program is the one nobody set a date on.

What you get

Four documents, written for your firm.

01
Your ML/TF risk assessment
Section 26C. Your designated services, customers, delivery channels and the countries you deal with, each rated — and each rating carrying the answers that produced it. Proliferation financing assessed and documented even where it's low, because the Act requires that in writing either way.
02
Your AML/CTF policies
Section 26F, built on the risk assessment rather than sitting beside it. Governance, your compliance officer's eligibility and duties, when customer due diligence falls due for your role specifically, reporting, records and training — ready for your senior manager to approve.
03
A gap analysis
What you have, what's missing, and what to do first — including any matter already on your books where the designated service has started and due diligence hasn't been done. That's usually the finding that matters most.
04
A compliance calendar
Your dates, not a generic list: your first independent evaluation deadline, your compliance officer notification deadline, your three-year review clocks, and the annual compliance report window.
The difference

Documents that change when your answers change.

There is a simple test for any generated AML/CTF program, and it is worth applying to ours as much as to anyone's: would it have come out the same if you had answered differently? The Act requires an assessment of the risks your business may reasonably face. A document that is identical whatever you type into it has not assessed anything — it has printed something.

So in your pack, every rating begins at a stated baseline for that service and then moves according to what you told us — and each movement is shown. Not "this is Medium-High", but which rule fired, which direction it moved the rating, and which question triggered it.

A real extract — how one rating was reached
→
Starting point — Medium
Customers reached through a mix of channels, before anything is known about which.
→
Overseas intermediaries are a significant channel · +1
Distance, different regulatory standards, and limited ability to verify what the intermediary actually did.
→
You rely on someone else to identify your customers · +1
Reliance moves the work but not the obligation.
→
You have introduced new or emerging technology · +1
New technology must be assessed as part of the delivery channel, and introducing it triggers a review.
Assessed inherent risk: High

Your risk assessment also lists the rules we tested that didn't apply to you. Showing what was ruled out is worth more to whoever evaluates you than showing only what was found.

The practical effect is that you can argue with us. If a rating is wrong for your firm you can see exactly why we reached it and say so — which is a far better position than being handed a number with no reasoning attached and having to take it on faith. It is also the position your independent evaluator will want you in, three years from now, when they ask how the assessment was actually done.

What it costs

Two flat fees. Launch pricing.

Report Readiness Pack
AUD $249
Self-serve · Launch pricing
Payable up front. Refundable in full until we start generating — after delivery it isn't, because the work is done.
→What the annual compliance report will ask, in plain English
→The registers and records to keep so the answers accumulate through the year
→Deadline reminders — yours, not just the window
→Your prepared answers at year end, included
→You review and file your own report
Your answers stay on file — when the first reporting window opens (July–September 2027) your prepared answers are generated at no further charge. Nothing to re-enter, nothing to reconstruct.
Start — AUD $249 →
AML/CTF Program Pack
AUD $595
Self-serve · Launch pricing
Payable up front. Refundable in full until we start generating — after delivery it isn't, because the work is done.
→Your ML/TF risk assessment, derived from your answers
→Your AML/CTF policies, built on it
→A gap analysis and a compliance calendar
→12 months of email support and regulatory-change alerts
→Your first annual compliance report's working paper when the window opens (Jul–Sep 2027)
→Delivered within one working day — you review and adopt your own documents
Your 12 months of support spans the first-ever Tranche 2 reporting window (July–September 2027) — your first annual compliance report's answers arrive as part of the pack, when it legally exists.
Start — AUD $595 →
About 20 minutes of questions. Your pack lands within one working day.
Done-with-you
AUD $995
Reviewed with you · Launch pricing
Paid in two halves: AUD $497.50 to begin, by card on the next screen, and the balance invoiced when you approve the pack — before the final documents are delivered.
→Everything in the Program Pack
→Reviewed and finalised with you in a working session
→We work through the ratings and you tell us where we've read your business wrong
→Your senior manager gets a document they can actually approve
→Your first annual compliance report prepared and filed with you when the window opens
→Then AUD $495/yr or AUD $49.95/mo to stay current
The same pack, plus the conversation that turns a good draft into a document you'd defend. Worth it if you'd rather not be the one deciding whether it's right.
Start — AUD $995 →

Already quoted on our earlier AUD $395 or AUD $1,495 offers? Those prices are honoured on the terms you were quoted.

What comes next

Your first report is due in 2027.

Compliance reporting runs on financial years, not on your enrolment anniversary — a distinction that catches people out. You submit between 1 July and 30 September each year, covering the previous 1 July to 30 June. For firms regulated from 1 July 2026, that means your first report covers FY2026-27 and is submitted between 1 July and 30 September 2027.

That is far enough away that there is nothing to buy for it today, and close enough that it belongs on a calendar. Your pack puts it on one, along with your three-year review clocks and your first independent evaluation deadline — which is set by the last two digits of your AUSTRAC Account Number and is the date almost nobody works out for themselves. We'll be in touch about report support when the window approaches; you commit to nothing now.

Who's actually doing the work

Expertly Designed. Commercially Grounded.

AML solutions developed and led by a Chartered Accountant with 20+ years of experience across public practice, business operations, audit, and government sectors.

Chartered Accountant Led
A CA ANZ member, qualified over twenty years, leads the work.
Government & Audit Backed
Built on experience in audit and government finance, where the file has to stand up to inspection.
Commercially Minded
Years spent running businesses, not only advising them — so the process fits around how your firm actually works.

We prepare, you adopt. A senior manager in your business approves the program in writing — that's what brings it into force, and it has to be someone in your firm. We don't act as your AML/CTF compliance officer either, and having written your documents we're disqualified from performing your independent evaluation. We'll refer you for that.

This is a document preparation service. It isn't legal advice. The terms of engagement set out exactly where the line sits.

FAQ

Common questions.

I enrolled before the deadline. Isn't that the obligation done?
Enrolment put you on the Reporting Entities Roll. It didn't give you an AML/CTF program, and the program is the substantive obligation — it was supposed to be in place before you provided a designated service, which for most firms means before 1 July 2026. If you enrolled and stopped there, you're in the same position as a great many firms: on the register, and without the documents the register implies you have.
What does an AML/CTF program actually have to be?
Two things, and only two things: an ML/TF risk assessment, and the AML/CTF policies that manage the risks it identifies. It has to be documented in writing, approved by a senior manager with their name, role and date, and complied with. You also need an AML/CTF compliance officer at management level, notified to AUSTRAC. If you've read about a program having a "Part A" and a "Part B", that structure was replaced in the reforms — independent evaluations now cover the whole program. Anything still using that framing predates the regime you're actually in.
Can't I just do this for free?
Sometimes, and you should know it. AUSTRAC publishes free, editable program starter kits, and if your firm meets their eligibility criteria they're a legitimate place to begin — broadly that means only the one kind of designated service, fifteen or fewer people, mostly individual Australian-resident customers, and no regular high-risk or overseas work. AUSTRAC states plainly that a firm outside those criteria cannot rely on the kit. Free generators exist elsewhere too. What none of them does is work out which of your services are captured, what risk each carries on your facts, and what your policies therefore have to say. That judgement is the work. Our gap analysis actually runs AUSTRAC's eligibility criteria against your answers and tells you if you qualify — including when the answer means you don't need us.
How is this different from a generated template?
Test it the obvious way: would the document have come out the same if you'd answered differently? Section 26C requires an assessment of the risks your business may reasonably face, so a program that's identical whatever you type hasn't assessed anything. In your pack every rating starts from a stated baseline and then moves, step by step, according to your answers — and each step names the rule, the direction, and the specific question that triggered it. There's a derivation log at the back of the risk assessment showing the whole chain, including the rules we tested that didn't apply. You can audit our reasoning instead of taking it on trust, and so can whoever evaluates you.
When's the first annual compliance report?
Compliance reporting runs on financial years, not on your enrolment anniversary. You submit between 1 July and 30 September each year, covering the previous 1 July to 30 June. For firms newly regulated from 1 July 2026, the first report covers 1 July 2026 to 30 June 2027 and is submitted between 1 July and 30 September 2027. Your pack includes the calendar so it doesn't arrive as a surprise, and we'll offer report support when the window approaches — there's nothing to commit to now.
What about the independent evaluation everyone's mentioning?
Every reporting entity needs one at least every three years, and for newly regulated firms the first deadline is staggered by the last two digits of your AUSTRAC Account Number — somewhere between 30 June 2029 and 31 December 2030. Your calendar works out which one is yours. We can't do the evaluation itself: having written your documents we're disqualified from evaluating them, which is the rule working as intended. We'll refer you.
I still haven't enrolled. Can you do that?
Not as a product any more — the transitional window closed on 29 July 2026. Enrol yourself in AUSTRAC Online; the standing rule is 28 days from when you first provide a designated service, and being enrolled late is a considerably better position than not being enrolled at all. Do that first, then come back for the program. Say so on the form and we'll point you at the right part of AUSTRAC's site.
Who signs it off?
A senior manager in your business, in writing, recording their name, role and date. That's not a formality we've added — it's what makes the program come into force. We prepare, you adopt. We also don't act as your AML/CTF compliance officer: AUSTRAC permits that person to be external, but it's a standing appointment with personal statutory duties and it isn't a role we take on.
Is this legal advice?
No. This is document preparation, led by a Chartered Accountant. It isn't legal advice, and the terms of engagement set out exactly where the line sits. There's no GST on any of it — we aren't GST-registered.
Ask first

Not ready to start? Ask.

Tell us where you're up to and we'll come back with a straight answer — including "you don't need us" if that's the answer.

Nothing to pay now, and no obligation. If it turns out the services you provide aren't captured, or you qualify for AUSTRAC's free starter kit, we'll tell you straight and we won't invoice you for work you don't have to do.

Start here
Know you need it? Skip the chat.

About twenty minutes of questions, and your pack is with you within one working day.

Start now — 20 minutes →
About 20 minutes of questions. Your pack lands within one working day.

“Compliance shouldn't paralyze your operations. Our frameworks are developed and led by a Chartered Accountant with 20+ years of experience bridging the gap between government audit requirements and real-world business operations.”

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Get the program written.

You're on the register. The documents behind it are the part AUSTRAC will actually ask to see — and there is no deadline coming that will make writing them any easier. Twenty minutes of questions, delivered within one working day.

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We prepare AML/CTF documents for your review and adoption. We don't give legal advice, we don't act as your compliance officer, and we can't perform your independent evaluation. Deplexify is not affiliated with, endorsed by, or acting on behalf of AUSTRAC.

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