AML Tranche-2 Origination Platform
AML Tranche-2 Origination Platform
The AU tranche-2 compliance product: one origination flow — lead capture → KYC → AML screening → compliance — sold to ~80k newly-captured small businesses (accountants, lawyers, real estate) and the lenders/AFSLs who serve them.
Key acceptance criteria
| # | criterion | source |
|---|---|---|
| 1 | End-to-end origination: capture, KYC/CDD, screening, decision, compliance record in one pipeline | industry/aml |
| 2 | Fail-safe decisions: missing facts force REFER, never silent approve | kb:fail-safe-decision-table |
| 3 | CDR bank-data access via dual-source vendor decision | kb:cdr-vendor-dual-source |
| 4 | Transaction monitoring with audit-defensible alerts | market analysis row 7 |
| 5 | Price-certain contracts (no surprise per-check billing) | market analysis row 12 |
| 6 | Compliance-by-construction: every check traceable to a regulation decode | market analysis row 13, kb:aml-ctf-act-2006 |
| 7 | 7-year record keeping; SMR/TTR workflow support | AML/CTF Act 2006 |
| 8 | Form runtime: YAML DSL in git, compiled bundles, DSL never distributed | kb:yaml-dsl-form-runtime, kb:dsl-compiler-never-distributed |
Pricing model
Two-part pricing: a monthly platform fee per reporting entity (tiered by size) PLUS a published per-KYC rate — every check bills at the published rate, no other per-check fees, and usage beyond included volume bills at the same published rate. The price-certainty promise is contractual, not marketing: both rates are published and locked for the term. The promise is certainty with teeth, not "always cheaper": price-match on comparable written quotes ("for the same scope, if a competitor quotes less in writing, we match or beat it") plus a published total-cost-of-ownership calculator vs incumbents — verifiable, scoped, and ACL-safe. Absolute "always cheaper" claims are rejected: competitor pricing is mostly quote-based (unverifiable), free starter packs exist (kb:aml-tranche2-starter-packs), and bundles are incomparable. Exact tiers set against the competitor matrix (10 vendors priced in kb:aml-tranche2-market-analysis); bank-deployment licensing priced separately per kb:product-selections-tradeoffs. Entry motion: starter-pack prospects (AUSTRAC starter kit, SimpleAML, FreeAML users — kb:aml-tranche2-starter-packs) upgrade into tier one; the starter pack is the funnel, not the competitor.
Published-rate cost comparison (TCO basis)
The TCO calculator compares published rates only — quote-based vendors are excluded, never estimated. Comparison variables: seats/staff, KYC checks per month, contract term, onboarding fees, per-check overage exposure.
| vendor | published rate | per-check | term/onboarding | TCO note |
|---|---|---|---|---|
| AUSTRAC starter kit | $0 | — | gov | enrolment only — false-comfort trap (kb:aml-tranche2-starter-packs) |
| SimpleAML | $0 | — | — | sole practitioners only |
| FreeAML | $0 subscription | $20 individual / $40 entity | monthly | pay-per-use; cost scales linearly with checks |
| AMLTranche | $59/$99/$149/mo +GST (1/3/5 seats) | $10/extra IDV, $29/extra seat | monthly | per-seat + credit creep |
| Flagship AML | A$66.70/mo or A$880/yr | DVS IDV $4+GST each | monthly/annual | 30 PEP/sanctions free/mo, then per-check |
| AML Shield | $799/yr program · $99/mo Micro · $1,591/yr Standard | none | annual/monthly | flat — closest to price certainty |
| easyAML | $179/$449/$999/mo +GST | $15–20/check, $15–35 overage | 12-month | term lock-in + overage |
| OverSEER AML | from $350/mo | KYC free unless DVS ($5/check) | monthly | only incumbent with transaction monitoring |
| TrustEasy | ~$1,200/yr + $330 onboarding | allowances: 2,400 CDD + 60 ID checks | annual | allowance overage beyond caps |
| First AML | quote-based (POA) | usage-based | annual enterprise | excluded — no published rate |
Rules: our side of the calculator publishes only once our rate card is set (pending — exact tiers against this matrix); the calculator shows total cost at the customer's own volumes, not headline prices; quote-based vendors are listed as "contact for pricing", never guessed. Sources: kb:aml-tranche2-market-analysis pricing table (verified Jul–Nov 2026).
How we beat the market
- Transaction monitoring (row 7) — included and traceable, not a bolt-on module.
- Price certainty (row 12) — published tiers, no per-check surprises. Early signal: price appears to be the primary signup driver (hypothesis — validate with analytics); the published-rate TCO calculator makes the advantage visible at comparison time.
- Compliance-by-construction (row 13) — checks generated from traceable regulation decodes; audit defensibility is structural.
- Review-footprint wedge — win the visible-review gap first, expand inside the entity.
- Enforcement tail — low uptake + live s167 notices (
kb:aml): the unenrolled/unprepared majority needs enrolment-to-compliance in days, not quarters; our origination flow + KB-generated program is the fastest path. - Training whitespace — nobody trains newly-captured businesses in AML (incumbent training targets professionals); v2 for us, recorded now as an unclaimed row.
Product vs competitors
Wide capability matrix — vendors as rows, capabilities as columns (condensed from the full 13-requirement matrix, kb:aml-tranche2-market-analysis). Legend: ✓ included · ~ partial or workflow-only · ✗ absent · ? unknown.
| vendor | KYC | DVS | CDR | PEP/sanctions | UBO | ongoing CDD | txn monitoring | AUSTRAC reporting | 7-yr records | integrations | training | pricing |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| AUSTRAC starter kit | ~ templates | ✗ | ✗ | ✗ | ✗ | ✗ | ✗ | ~ templates | ~ | ✗ | ~ | $0 |
| SimpleAML | ~ | ✗ | ✗ | ~ | ✗ | ✗ | ✗ | ✗ | ✗ | ✗ | ✗ | $0 (sole practitioners) |
| FreeAML | ✓ $20–40/check | ? | ✗ | ? | ? | ✗ | ✗ | ~ | ~ | ✗ | ✓ | $0 sub + per-check |
| AMLTranche | ~ IDV credits | ? | ✗ | ✓ DFAT | ? | ~ | ✗ | ~ | ~ | ✗ | ? | $59–149/mo + credits |
| Flagship AML | ✓ DVS $4/check | ✓ | ✗ | ✓ 30 free/mo | ✓ calculator | ~ | ✗ | ~ | ✓ | ✗ | ✓ | A$66.7/mo + DVS fees |
| AML Shield | ~ workflow incl. | ✗ | ✗ | ? | ? | ~ | ✗ | ~ | ~ | ✗ | ✓✓ expert | $99–149/mo flat |
| easyAML | ✓ $15–20/check | ? | ✗ | ✓ | ~ | ~ | ✗ | ~ | ~ | ✓ Xero | ✓ free | $179–999/mo + overage, 12-mo term |
| OverSEER | ✓ free / $5 DVS | ✓ $5/check | ✗ | ✓ | ~ | ✓ | ✓ rules engine | ✓✓ XML | ✓ | ✓✓ Xero/QBO/MYOB | ? | from $350/mo |
| TrustEasy | ✓ 60 checks incl | ? | ✗ | ✓ | ~ | ~ | ✗ | ✓ SMR/TTR/IFTI | ✓ | ✓✓ Xero/XPM/APM/MYOB | ✓ | ~$1,200/yr + $330 onboarding |
| First AML | ✓ biometric 96%+ | ? | ✗ | ✓ global | ✓✓ 200+ jurisdictions | ~ | ✗ | ~ | ✓ | ✓ | ✗ | quote-based, enterprise |
| Us (planned) | ✓ $0.33–0.80 API | ✓ DVS-via-GSP | ✓✓ dual-source Basiq/Frollo | ✓ DFAT + $0.10–0.50 | ~ v2 | ✓ ledger-native | ✓✓ from ledger data | ✓ v2 | ✓✓ tamper-evident | ✓✓ Xero first | ~ v2 | monthly fee + published per-KYC rate |
Read: CDR bank-data access (Consumer Data Right — kb:cdr-vendor-dual-source) is absent from every incumbent — no vendor productizes the business-account authority chain; it is our clearest differentiator alongside transaction monitoring (OverSEER only, at $350/mo) and compliance-by-construction (nobody). The flat-rate vendors (AML Shield, Flagship) are workflow/document platforms — program builders and manual KYC/CDD checklists (the customer's staff verify documents; complex entities are out of scope) — not verification-and-monitoring systems; that is why flat works for them and why our per-KYC pricing carries real variable cost. We concede UBO depth and training content near-term (v2); we win transaction monitoring, CDR, price certainty and compliance-by-construction outright.
Simple scorecard — what they have vs us
Distilled from the wide matrix above: ✅ have it · 🟡 partial or workflow-only · ❌ don't have it · ✅✅ best-in-class.
| vendor | txn monitoring | price certainty | compliance-by-construction | CDR bank-data | KYC/DVS checks | PEP/sanctions | UBO | integrations | AUSTRAC reporting | training |
|---|---|---|---|---|---|---|---|---|---|---|
| AUSTRAC starter kit | ❌ | ❌ | ❌ | ❌ | 🟡 | ❌ | ❌ | ❌ | 🟡 | 🟡 |
| SimpleAML | ❌ | ❌ | ❌ | ❌ | 🟡 | 🟡 | ❌ | ❌ | ❌ | ❌ |
| FreeAML | ❌ | 🟡 | ❌ | ❌ | ✅ | 🟡 | ❌ | ❌ | 🟡 | ✅ |
| AMLTranche | ❌ | 🟡 | ❌ | ❌ | 🟡 | ✅ | 🟡 | ❌ | 🟡 | 🟡 |
| Flagship AML | ❌ | 🟡 | ❌ | ❌ | ✅ | ✅ | ✅ | ❌ | 🟡 | ✅ |
| AML Shield | ❌ | ✅ | ❌ | ❌ | 🟡 | 🟡 | 🟡 | ❌ | 🟡 | ✅✅ |
| easyAML | ❌ | ❌ | ❌ | ❌ | ✅ | ✅ | 🟡 | ✅ | 🟡 | ✅ |
| OverSEER | ✅ | 🟡 | ❌ | ❌ | ✅ | ✅ | 🟡 | ✅✅ | ✅✅ | 🟡 |
| TrustEasy | ❌ | ✅ | ❌ | ❌ | ✅ | ✅ | 🟡 | ✅✅ | ✅ | ✅ |
| First AML | ❌ | 🟡 | ❌ | ❌ | ✅ | ✅ | ✅✅ | ✅ | 🟡 | ❌ |
| Us | ✅✅ | ✅✅ | ✅✅ | ✅✅ | ✅ | ✅ | 🟡 v2 | ✅✅ Xero first | 🟡 v2 | 🟡 v2 |
Read: we are the only row with ✅✅ on transaction monitoring, price certainty, compliance-by-construction and CDR; OverSEER is the only incumbent with transaction monitoring at all; CDR bank-data is ❌ for every incumbent; compliance-by-construction is ❌ for everyone.
Requirement breakdown
Detailed layer under Key acceptance criteria — each capability decomposed into testable sub-requirements. Phase: v1 = launch scope, v2 = post-launch. Grounded in kb:aml-ctf-act-2006, kb:cdr-vendor-dual-source, kb:fail-safe-decision-table, kb:product-selections-tradeoffs.
| capability | sub-requirements | phase |
|---|---|---|
| KYC identity verification (by type) | Individual: capture ID documents; liveness/biometric check; verify via provider API; PEP/sanctions screen at onboarding; risk-rate; create CDD record; re-verify on triggers. Business entity (KYB): ABN/ACN verification; directors + beneficial owners identified; nominated representative onboarded. Trust / partnership / sole trader: variants of entity + individual flows. CDR-assisted: authority chain (entity KYB → nominated rep → rep KYC → CDR consent, kb:cdr-vendor-dual-source). All types: retain 7 years; audit trail from day one | v1 |
| DVS document verification | submit check via GSP; verify document authenticity; match document to person; failure fallback path; record result in audit trail; published per-check cost | v1 |
| CDR bank-data access | consumer accounts via Basiq ($0.50/user/mo); business accounts via Frollo + authority chain (entity KYB → nominated representative → representative KYC → CDR consent); consent capture/revocation; normalize transactions to one internal model; Statements Upload fallback for non-CDR banks | v1 |
| PEP/sanctions/adverse media | screen against DFAT list (free); adverse media check; ongoing re-screening schedule; match-review workflow with analyst decision; false-positive suppression | v1 |
| UBO tracing | identify ≥25% beneficial owners; registry lookups across jurisdictions | v2 |
| Ongoing CDD | periodic review schedule by risk rating; event-driven re-verification (CDR anomalies, document expiry); refresh risk rating; document review outcomes | v1 |
| Transaction monitoring | ingest ledger transactions (Xero first); apply typology rules; score alerts; analyst review workflow; draft SMR; 7-year retention | v1 |
| AUSTRAC reporting | SMR/TTR/IFTI lodgment workflows; XML export | v2 |
| Reporting workflow | obligation calendar with statutory deadlines (SMR/TTR/IFTI triggers); draft → review → lodge → confirm lifecycle; filing-status tracking; reminders/escalation; immutable audit trail of every report and decision | v1 |
| 7-year records / audit trail | tamper-evident storage; audit trail of every check and decision; export on demand; survive provider churn | v1 |
| Accounting integrations | Xero first (ledger + contacts); QBO/MYOB | v2 |
| Staff training | AML/CTF program training content — unclaimed for newly-captured businesses: incumbent training targets AML professionals, not first-time reporting entities | v2 |
How we notify the market
- Cheap-site funnel: disposable segment landing pages ("AML for accountants", "tranche-2 checklist") on DigitalPlat — near-zero cost, fast spin-up; product login/paywall stays in our stack.
- SEO content pages + short-link campaigns per segment.
- Review-generation landing pages as the visible-review wedge.
- Consent-first only: Spam Act 2003 governs every send — no bought lists (
kb:spam-act-2003, industry/marketing).
Sources
- kb:aml-tranche2-market-analysis, kb:aml-ctf-act-2006, kb:cdr-vendor-dual-source, kb:product-selections-tradeoffs, kb:fail-safe-decision-table, kb:yaml-dsl-form-runtime, kb:dsl-compiler-never-distributed, kb:spam-act-2003
- industry/aml.md, industry/marketing.md