Inclusions | Basic $1,000 / Month | Standard $2,000 / Month | Enhanced $4,000 / Month | Premium $5,000 / Month | Enterprise $7,000 / Month | What This Includes (Plain English, Frequency & Limits) |
Core AML/CTF Program Tailored To Your Business (Incl. ML/TF/PF Risk Assessment) | ✔️ | ✔️ | ✔️ | ✔️ | ✔️ | - We draft your foundational AML/CTF Program and your ML/TF/PF Risk Assessment document customised to your business model.
- Included: Drafting of core Program and Risk Assessment (one combined document suite).
- Frequency: One-off setup
- Caps: Includes one round of feedback.
- Annual reviews are separate (see below).
- Out of Scope: (procedures – see next row), transaction testing, or remediation of legacy issues).
|
Hands-On Implementation Support (Onsite Or Online) | – | ✔️ | ✔️ | ✔️ | ✔️ | - We help you actually do the work—setting up your systems, running your first KYC, CDD checks, or embedding the program into your daily operations.
- Included: Up to 2 x 90-minute virtual or onsite implementation sessions per month (e.g., “We sit with your team to set up the KYC, CDD folder structure”).
- Frequency: Monthly.
- Caps: 3 hours total per month. Additional hours billed at $200/hr (Junior Consultant) or $300/hr (Senior).
- Out of Scope: Full outsourcing of the compliance function (see Fractional GC plans).
|
Procedures & Templates (CDD, TMP & SMR) | – | ✔️ | ✔️ | ✔️ | ✔️ | - We provide the working documents your team uses daily: Customer Due Diligence checklists, Transaction Monitoring logs, and Suspicious Matter Report templates.
- Included: One set of templates.
- Frequency: One-off setup.
- Caps: Up to 5 templates included. Customisation beyond standard templates quoted separately.
- Out of Scope: Populating the templates with live customer data (that’s your job) or retrospective reviews of old files.
|
Standard AML/CTF Staff Training | – | ✔️ | ✔️ | ✔️ | ✔️ | - A pre-packaged presentation to teach your staff the basics of AML/CTF, what their obligations are, and how to spot a red flag.
- Included: One 60-minute virtual training session for up to 20 staff.
- Frequency: Annual.
- Caps: Includes standard slides. Additional sessions or customisation of slides is extra.
- Out of Scope: Role-specific training (e.g., for high risk roles, board and executives only) or development of an online training module.
|
Customer Identification & Compliance Sign-Off | – | – | ✔️ | ✔️ | ✔️ | - We act as a quality check. You send us the customer identification docs, and we review them to confirm they meet compliance standards before you sign off.
- Included: Up to 5 file reviews per month.
- Frequency: Monthly.
- Caps: 5 reviews/month. Additional reviews charged at $150 per file (bulk rate) or $200/hr.
- Out of Scope: Complex beneficial ownership tracing requiring legal research.
|
Quarterly Compliance Check-Ins | – | – | ✔️ | ✔️ | ✔️ | - A scheduled 45-minute video call to review your compliance health, discuss any new risks, and answer quick questions.
- Included: One 45-minute meeting per quarter.
- Frequency: Quarterly.
- Caps: Preparation time up to 30 mins included. Major issues identified during the call are treated as new matters.
- Out of Scope: Formal audit or detailed investigation of issues raised.
|
Annual AML/CTF Compliance Report For AUSTRAC | – | – | ✔️ | ✔️ | ✔️ | - We review or complete your annual compliance report before submission to AUSTRAC.
- Included: hands on training on how to complete the report and how to lodge with AUSTRAC.
- Frequency: Annual.
- Caps: One round of amendments. If we need to audit your files to write the report, that is extra.
- Out of Scope: Independent Review (Chapter 8.6) or external audit.
|
Tailored AML Training For Staff | – | – | – | ✔️ | ✔️ | - Bespoke training designed specifically for your business. We review your actual risk profile and create a session relevant to your specific products and customer types.
- Included: Design and delivery of one 90-minute tailored session.
- Frequency: Annual.
- Caps: Up to 20 attendees. Additional attendees or custom e-learning modules quoted separately.
- Out of Scope: Training for non-standard roles (e.g., IT staff on financial crime).
|
Regulator Update Briefings | – | – | – | ✔️ | ✔️ | - A 30-minute briefing (via email summary or call) whenever there is a significant change to AUSTRAC guidance, the AML/CTF Act, or Rules that impacts your business.
- Included: Proactive notification and a 2-paragraph summary of “what this means for you.”
- Frequency: As-needed (triggered by regulatory changes).
- Caps: Up to 4 briefings per year. Deep-dive analysis of changes is extra.
- Out of Scope: Implementing the changes into your documents (e.g., rewriting your program due to a law change).
|
Dedicated Support Line For Ad-Hoc Advice | – | – | – | ✔️ | ✔️ | - A direct email/phone line for quick questions like, “Is this customer politically exposed?” or “Do we need to report this transaction?”
- Included: Up to 5 discrete advice “touches” per month (calls or emails).
- Frequency: Monthly.
- Caps: Capped at 15 minutes per touch. Complex research matters (requiring >30 mins) moved to project work.
- Out of Scope: Document drafting, legal research projects, or representation.
|
Additional Legal & Compliance Documentation | – | – | – | – | ✔️ | - We draft related policies that sit alongside your AML program, such as your Privacy Policy, Whistleblower Policy, or Risk Appetite Statement.
- Included: Up to 2 additional standard documents per year.
- Frequency: As requested (up to 2 per year).
- Caps: Standard templates only. Complex, bespoke contracts (e.g., JVs, or Reporting Entities) are extra.
- Out of Scope: Commercial contracts (supplier agreements, leases).
|
Ongoing Strategic AML/CTF Advisory & Consultation | – | – | – | – | ✔️ | - We act as your virtual AML CTF Compliance Officer. This is high-level advice on strategy, such as “Should we enter this new market or introduce this product or platform?” or “How do we restructure our AML compliance arrangement or function?”
- Included: One 60-minute strategic planning session per quarter.
- Frequency: Quarterly.
- Caps: Strategy only (advice). Implementation of the strategy is project-based.
- Out of Scope: Execution of the strategy (e.g., project management).
|
Remediation Support & Project Work | – | – | – | – | ✔️ | - We roll up our sleeves to fix past problems, such as reviewing a backlog of 10 customer files that were missing documents when the business started.
- Included: Up to 4 hours of remediation support per month.
- Frequency: Monthly.
- Caps: 4 hours/month. Beyond this, billed at project rates with a separate SOW.
- Out of Scope: Large-scale remediation projects (e.g., cleaning 500+ files).
|
Regulator Engagement Assistance | – | – | – | – | ✔️ | - If AUSTRAC contacts you (for an audit, information request, or site visit), we help you prepare the response and can sit in on meetings.
- Included: Review of 1 draft response per year and a 30-minute prep call.
- Frequency: As-needed (up to 1 event per year).
- Caps: One event. Formal representation or appearing on your behalf is out of scope (requires separate engagement).
- Out of Scope: Defending against enforcement action or penalties.
|
