AML Tranche-2 starter packs — the entry-level market
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
| pack | price | what it is | what it lacks |
|---|---|---|---|
| AUSTRAC starter kit | $0 (government) | enrolment guidance + templates | everything after enrolment: KYC, screening, monitoring, records |
| SimpleAML | $0 | free tool, sole practitioners | entity coverage, monitoring, integrations |
| FreeAML | $0 subscription, $20 individual / $40 entity KYC per check | pay-per-use KYC | subscription features, monitoring, price certainty at volume |
| AMLTranche | $59/$99/$149/mo +GST (1/3/5 seats) + $10/extra IDV | per-seat + IDV credits | transaction monitoring, flat pricing (per-check creep), compliance proof |
| Flagship AML | A$66.70/mo or A$880/yr + DVS $4+GST/check | flat subscription, 30 PEP/sanctions free/mo | monitoring, 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
- Every newly captured business starts here: free kit or ~$60–100/mo entry tier. This is the funnel top for the whole segment.
- None of them combine the three win rows (
kb:aml-tranche2-market-analysisrows 7/12/13): transaction monitoring, price certainty, compliance-by-construction. The starter packs are where businesses discover the gaps. - The upgrade trigger is enforcement: AUSTRAC s167 notices (
kb:aml) and readiness-gap research push businesses from "minimum viable enrolment" to "provable compliance program".
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 capability | requirement row | why it matters |
|---|---|---|---|
| 1 | Ongoing CDD — continuous customer-risk monitoring | 6 | the pack is one-time onboarding only |
| 2 | Transaction monitoring — typology detection from ledger data | 7 | absent from every starter/free tier |
| 3 | AUSTRAC reporting — SMR/TTR/IFTI lodgment + XML | 8 | reports still have to be filed somehow |
| 4 | 7-year records / tamper-evident audit trail | 9 | audit-defensibility is the product |
| 5 | Accounting integrations (Xero/QBO/MYOB) | 11 | feeds that make monitoring possible |
| 6 | Price certainty — flat, published, no per-check creep | 12 | FreeAML scales linearly with volume |
| 7 | Compliance-by-construction — criteria traceable to the Act | 13 | templates are not proof |
| 8 | Ongoing screening — PEP/sanctions/adverse-media re-screening | 4/6 | onboarding-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
- 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). - Land at the starter-pack price point — a starter tier competitive with AMLTranche/Flagship entry pricing, not a premium ask.
- 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).
- 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-platformnotify-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:
- Program documents generated from traceable regulation decodes (
kb:aml-ctf-act-2006), not generic templates - CDD records created and retained — the 7-year requirement starts at the first check
- Audit trail started from day one — every check, decision and document change recorded
- The gap list disclosed — documented compliance is not ongoing compliance; the pack must say what it does not cover
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
- Pricing the starter tier at incumbent mid-market levels — you price yourself out of the funnel.
- Trying to beat free on features — beat it on outcome and upgrade path.
- Ignoring starter-pack users in GTM — they are the highest-intent upgrade pipeline in the segment.
Sources
- kb:aml-tranche2-market-analysis (pricing table, feature matrix, win rows)
- kb:aml (low-uptake stats, s167 enforcement), kb:aml-tranche2-platform (entry motion, notify-market)
- /Users/devin/aml-competitor-matrix.md (vendor pricing verification, Jul–Nov 2026)