---
title: Plain AML: we run the monthly AML/CTF routine
url: https://plainaml.com.au/
updated: 2026-10-13
---

> Markdown version of https://plainaml.com.au/. Same content as the web page. Plain AML is a managed AML/CTF service for small NSW practices. Contact: mike@plainaml.com.au. General information only, not legal advice.

AML/CTF · Tranche 2

# We run the monthly routine. You make the calls and sign.

The monthly AML/CTF routine is the part nobody has time for. We do that recurring work for small NSW practices. Since 1 July 2026, accountants, conveyancers, real estate professionals and lawyers who provide certain services must run an AML/CTF program and report to AUSTRAC. You stay in charge, keep the compliance officer role and sign off every month.

[Take the 5-minute check](https://plainaml.com.au/check/) [Book a call](https://plainaml.com.au/#contact)

### We do

- Write your risk assessment and policies from your own intake
- Verify each new client and the people behind companies and trusts
- Screen for sanctions and PEPs, and re-screen existing clients
- Keep your training records and deadline calendar
- Prepare every suspicious matter report and the annual report for you to review and lodge
- Prepare the monthly pack you review and sign

### You do

- Appoint, and stay, your compliance officer
- Hold your AUSTRAC enrolment and AUSTRAC Online account
- Review and lodge every report to AUSTRAC. The final call is yours.
- Tell us when your business changes: a new service, client type, office or staff
- Review and sign the monthly pack
- Arrange your independent evaluation when it's due (at least every 3 years)

## Who it's for, and who it isn't

### A good fit

- NSW accountants who set up companies or trusts or provide a registered office address
- NSW conveyancers and buyer's agents who help clients buy or sell property
- Firms of 2 to 15 staff opening at least 3 new client files a month
- Firms with a kit or a program on paper and no monthly routine

### Not for you if

- You open fewer than 2 new client files a month. The monthly plan is probably more than you need, so ask us about lighter options.
- You have more than about 15 staff or an unusual risk profile. You'll likely need a program built for you.
- You want us to be your compliance officer. We don't offer that.
- You want legal advice. We run the process. Your lawyer advises.
- You're not yet enrolled with AUSTRAC. Enrol first. If you're past the deadline, we look at where you stand before taking you on, and we don't take on past non-compliance.

Whether the law applies to your business depends on the services you provide. Confirm with [AUSTRAC's guidance on professional designated services](https://www.austrac.gov.au/new-austrac/designated-services-newly-regulated-entities/professional-designated-services) or your own adviser. Tax returns and bookkeeping on their own generally aren't covered.

## Why not just use the free kit or a software tool?

AUSTRAC publishes free starter programs for small, low-complexity firms. A document is the easy part. What takes a small firm's time is running it: checking each new client, screening, training, and keeping records you could hand to AUSTRAC. That's what we do each month.

AUSTRAC's starter kit is free, and you can use it. It gives you a document. Software gives you a tool to operate. We run it for you and hand back a pack to review and sign.

## How it works

### Check where you stand

Ten questions, five minutes. You see your gaps and what to fix first. No sign-up.

### We set up your program

A risk assessment and policies written from your own intake, built around how NSW conveyancers and accountants actually take on clients. No setup fee.

### We run it each month

Client checks, screening, training records and report drafts. You get a monthly pack to review and sign.

Send us new client files as they come in, through the month. We run the checks on each one and you approve it. At month end we pull it all into one pack for you to review and sign.

## Built for NSW practices

We work with two kinds of firm: NSW conveyancers and buyer's agents, and NSW accountants who set up companies and trusts. Your intake and your monthly pack follow the matters those firms really handle, such as property purchases and sales, trust purchasers, and company and trust setups.

## What you sign each month

One pack, every month, even when you open no new files. It shows work tested, not just counted: checks re-performed by a second person, what changed in your business, decisions made, and what we did not do.

[See a sample pack](https://plainaml.com.au/sample.html)

## Who stands behind it

### One person runs it

Plain AML is run by Mike Jones in NSW, so you deal with the same person every month. [About us](https://plainaml.com.au/about.html)

## Fees

Every cost, in one table. Prices are ex GST.

|                                  | Solo                                                                                                                                                                                                                                          | Practice      | Plus                         |
|----------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------|------------------------------|
| Monthly fee                      | \$290                                                                                                                                                                                                                                         | \$590         | \$990                        |
| Who it suits                     | Sole practitioner                                                                                                                                                                                                                             | 2 to 10 staff | Higher volume or higher risk |
| Client files included each month | 5                                                                                                                                                                                                                                             | 20            | 50                           |
| Included in every tier           | Staff training register and annual refresher. Suspicious matter report (SMR) drafting. Annual compliance report preparation. **We prepare every SMR and the annual report. You review and lodge.** Training course seats are charged at cost. |               |                              |
| Setup                            | \$0. Building your program is included: risk assessment, policies, governance records and forms.                                                                                                                                              |               |                              |
| Term                             | 3 months, then month to month with 30 days' notice                                                                                                                                                                                            |               |                              |
| Identity checks                  | We run the checks for the client files in your plan. Extra files are \$45 each.                                                                                                                                               |               |                              |
| If AUSTRAC contacts you          | Up to 3 hours a year of help is included. It is process help, not legal advice. Beyond that, we quote before we start.                                                                                                                        |               |                              |
| Independent evaluation           | Not included. Arranged with an independent evaluator and billed by them.                                                                                                                                                                      |               |                              |
| Quarterly review call            | No                                                                                                                                                                                                                                            | No            | Yes                          |


### Example: sole accountant

Two new clients a month. **\$290 a month**, nothing else. No setup.

### Example: busy month on Solo

Seven client files in a month. \$290 plus 2 extra files at \$45: **\$380**.

Companies and trusts can mean more than one person to verify, and we count that as one file. Solo works out at \$58 a file if you use all 5, and \$290 a file if you open one.

### Founding offer: first 10 firms

Month to month with 30 days' notice instead of the 3-month term, and your monthly rate locked for 12 months. If you leave within your first 3 months, a \$245 setup fee becomes payable.

### First-pack guarantee

If your first signed monthly pack isn't what we showed you, tell us within 10 business days of signing it. You leave with month one refunded and keep your program documents.

### Service credit

If we miss a delivery date we committed to in writing, including your monthly pack by the 10th business day of the month, that month's fee is credited. It doesn't cover reports you submit to AUSTRAC.

## Questions

Does this make us compliant?

No one can promise that. We run the routine and keep the evidence. Your business stays legally responsible, and you keep the compliance officer role and the final call on every report.

Will you be our compliance officer?

No. AUSTRAC says the officer needn't be an employee but must be engaged at management level with authority, independence and resources. We don't offer the role.

Is this legal advice?

No. We run the compliance process. If you need advice on how the law applies to a particular matter, talk to your lawyer.

What about the independent evaluation?

AUSTRAC requires an independent evaluation of your program at least every 3 years. We can't be your evaluator because we run the program. It isn't in our fee. When yours is due, we'll introduce independent evaluators. [AUSTRAC's guidance](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/develop-your-amlctf-programs/step-5-conduct-independent-evaluation)

Can we leave, and take our records?

Yes. After the 3-month initial term it's month to month with 30 days' notice, and your records are yours.

Do we have to be in NSW?

We're starting with NSW practices. Get in touch if you're elsewhere and we'll tell you whether we can help yet.

## Book a call

A 15-minute call to see whether it's a fit. No pitch deck.

[Book 15 minutes](https://calendar.app.google/PAuYui5NMx3XbRfd6) <mike@plainaml.com.au>
