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AML Tranche-2 starter packs — the entry-level market

marketactive owner: philip · updated 2026-11-14

relates: aml-tranche2-market-analysis · aml-tranche2-platform · aml

AML Tranche-2 starter packs — the entry-level market

The starting point of the tranche-2 market: free and entry-level compliance offerings that newly captured businesses adopt first. They define the floor — and the upgrade path is where we win.

The packs

packpricewhat it iswhat it lacks
AUSTRAC starter kit$0 (government)enrolment guidance + templateseverything after enrolment: KYC, screening, monitoring, records
SimpleAML$0free tool, sole practitionersentity coverage, monitoring, integrations
FreeAML$0 subscription, $20 individual / $40 entity KYC per checkpay-per-use KYCsubscription features, monitoring, price certainty at volume
AMLTranche$59/$99/$149/mo +GST (1/3/5 seats) + $10/extra IDVper-seat + IDV creditstransaction monitoring, flat pricing (per-check creep), compliance proof
Flagship AMLA$66.70/mo or A$880/yr + DVS $4+GST/checkflat subscription, 30 PEP/sanctions free/momonitoring, per-check DVS fees, compliance-by-construction
AML Shield Micro$99/mo (3 staff) / $1,591/yr Standard (15 staff)flat, "no per-check surprises"transaction monitoring, integrations beyond basics

Why they are the starting point, not the competitor

What the free pack is missing

The pack covers enrolment + templates + basic one-time KYC checks. Everything that makes compliance ongoing and defensible is absent:

#missing capabilityrequirement rowwhy it matters
1Ongoing CDD — continuous customer-risk monitoring6the pack is one-time onboarding only
2Transaction monitoring — typology detection from ledger data7absent from every starter/free tier
3AUSTRAC reporting — SMR/TTR/IFTI lodgment + XML8reports still have to be filed somehow
47-year records / tamper-evident audit trail9audit-defensibility is the product
5Accounting integrations (Xero/QBO/MYOB)11feeds that make monitoring possible
6Price certainty — flat, published, no per-check creep12FreeAML scales linearly with volume
7Compliance-by-construction — criteria traceable to the Act13templates are not proof
8Ongoing screening — PEP/sanctions/adverse-media re-screening4/6onboarding-only screening decays

This gap list is the upgrade pitch: every row is something the pack cannot grow into, which is why the upgrade path (not the pack) is the product.

The false-comfort trap

Businesses implement the pack, feel in the clear, and stop. The pack covers enrolment and templates — but ongoing CDD, transaction monitoring, real screening, and 7-year records remain. The comfort is false, and it is our wedge: enforcement (s167 notices, audits) eventually exposes the gap between "enrolled with a kit" and "audit-ready program". GTM rule: never attack the pack (free, government-adjacent) — position as "the pack got you enrolled; we make you audit-ready", and convert false comfort into provable compliance.

Our entry motion

  1. Fill the pack for them, free — we complete the AUSTRAC starter pack on the customer's behalf (enrolment assistance + program templates generated from our regulation decodes), at no cost. This removes the friction that stalls enrolment and gives us the customer relationship at the funnel top. Guardrails: the reporting entity signs and owns the program (responsibility never transfers); the fill is enrolment + templates only — we never claim it makes them compliant (templates are not proof, row 13); the gap list above is disclosed, which is also the pitch; outreach obeys Spam Act consent-first (kb:spam-act-2003).
  2. Land at the starter-pack price point — a starter tier competitive with AMLTranche/Flagship entry pricing, not a premium ask.
  3. Win the upgrade, not the starter — starter users hit the monitoring/price-certainty/compliance-proof wall; our tier one is the answer with migration in days (origination flow + KB-generated program).
  4. Never compete on free — the AUSTRAC kit and SimpleAML are free; our starter tier sells the outcome (audit-ready file, no missed SMR) at entry pricing, and the cheap-site funnel (kb:aml-tranche2-platform notify-market) captures the search traffic starter-pack users generate.

What a starter pack must guarantee

Starter packs must ensure your compliance is documented — the floor we hold every pack to, including our own free pack-fill:

Guardrail: "documented" is the honest claim — never "compliant" (templates are not proof, row 13). Documentation is the foundation the upgrade builds on: a business that starts documented can prove its program, and proof is what audits and s167 notices demand.

Anti-patterns

Sources