AML as a Service – Full Inclusions & Key Limits
Updated as at 3 March 2026
This table sets out the inclusions, scope and key limits for the AML as a Service package ($399/m + GST). It should be read together with the main AML/CTF Compliance service page, the “Quick‑Start AML Packages” section and the pricing panel when deciding if this package is appropriate for your business. This is a monthly subscription service for a single reporting entity, subject to the minimum initial term that applies to AML/CTF Compliance Plans and retainers.
| Inclusion | What This Means In Practice | What Is Included (Units / Frequency / Caps) | Out‑Of‑Scope / Custom Quote Only |
|---|---|---|---|
| KYC Onboarding Of New Customers | We assist with KYC / CDD checks for new individual and business customers and provide AML/CTF compliance sign‑off so you can onboard them compliantly. | KYC checks for up to 50 new customers per year for one reporting entity, based on client‑provided documents and data; our time is included, but any third‑party KYC tools or search provider fees are invoiced to you at cost. | Onsite visits; enhanced or ongoing customer due diligence (ECDD/OCDD); KYC for additional reporting entities; KYC volumes above 50 new customers per year (quoted separately). |
| Watchlist Screening (PEP / Sanctions / Adverse Media) | We screen your new customers against the Australian Consolidated List, PEP and adverse media databases as part of standard onboarding. | Screening using our tools at onboarding and/or periodic intervals for customers covered by this plan, up to 50 screening events per year included in the fee (third‑party tool costs passed through where applicable). | Investigation of red flags; bulk legacy or historical back‑book screening; additional screening volumes beyond 50 per year; specialist investigations triggered by true hits; ECDD/OCDD (quoted separately). |
| Transaction Monitoring | We review and investigate red flags in customer transactions to identify unusual or suspicious activity and advise whether an SMR to AUSTRAC is required. | Review and advice on up to 10 transactions or red flags per year under this plan; additional red flags can be reviewed at our hourly rates. | Building full transaction monitoring systems or rules engines; remediation of historic backlogs; complex forensic investigations; ongoing managed monitoring services. |
| Ongoing Compliance Support | We answer day‑to‑day AML compliance questions and guide your team on how to respond to common scenarios. | Reasonable email and phone support for up to 5 discrete queries per month, each capped at 30 minutes of advice. | Major policy drafting projects; complex written legal opinions; project management of remediation programs; large‑scale change or transformation projects. |
| Quarterly Reporting | We provide a concise quarterly report summarising key AML activities, issues and recommendations. | One one‑page quarterly summary report for management, covering key metrics, issues and recommended follow‑up actions, where requested. | Board or Committee reports and slide packs; detailed audit‑style reports; regulator‑facing reports for specific investigations or enforcement matters. |
| Training / Briefings | Ongoing AML/CTF training is not included in this subscription. | No formal AML/CTF training sessions are included in this package; all AML/CTF training is quoted separately. | Any AML/CTF training programs, awareness sessions, workshops or tailored briefings (always scoped and priced separately). |
| Other Standard Inclusions | This package is focused on ongoing operational AML support only. | No additional inclusions beyond those listed above are bundled into this subscription. | Any additional support outside the inclusions above, which is scoped and quoted separately or delivered under a different service. |
Assumptions & Limits For This Package
Who this package is designed for
- Single reporting entity providing one or more designated services
- Non‑complex products and services
- Straightforward structure (one legal entity)
- Low–medium AML/CTF complexity
- Not suitable for large, complex reporting groups or banking groups
Prerequisites before using AML as a Service
- You already have a documented AML/CTF Program and ML/TF/PF Risk Assessment in place, approved by Click Legal or another suitable advisor.
- You already have basic onboarding arrangements and internal processes; this service is designed to provide light‑touch AML/CTF Compliance Officer support, not to design your entire AML framework from scratch.
When this package should be custom‑quoted (not bought online)
- High‑risk reporting entities (by industry, products or geography)
- Reporting groups or multiple legal entities / branches
- Multiple complex products and designated services
- Significant legacy AML/CTF issues or historical non‑compliance
- Prior serious AUSTRAC findings
- Current AUSTRAC enforcement, remediation programs or intensive supervisory attention
Volume and suitability limits
- The package is designed for businesses onboarding up to 50 new customers per year.
- If your new customer volume or screening requirements grow materially beyond this level, we will review pricing and may recommend moving to a standard AML/CTF Compliance Plan or a custom engagement.
Minimum term and notice
- AML as a Service follows the same minimum initial term and notice period that apply to AML/CTF Compliance Plans and retainers under your Services Agreement (for example, a 6‑month initial term with written notice required thereafter, as specified in your agreement).
Examples of work always treated as separate engagements
- Independent AML/CTF Reviews or statutory Independent Evaluations
- AML/CTF training programs and workshops
- Drafting new AML/CTF Policies, Programs or detailed procedures from scratch
- Board and Committee reporting packs
- Major remediation projects and historical clean‑ups
- AUSTRAC enforcement, audit responses or contentious matters
- Large‑scale bespoke projects or full AML/CTF framework design
All packages can be tailored to your business needs. The listed price is a standard monthly estimate for small to medium enterprises; final pricing may vary based on the size, complexity and risk profile of your business. Full engagement terms for this package are set out in the Terms and Conditions of Engagement.
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What Our Clients Say About Working With Us
Jason Gold
Managing Director, IT Pro Tech"At IT Pro Tech, we partner with businesses who share our commitment to integrity. Click Legal stands out in the legal space for exactly that. Hannah and the team impressed us with their deep understanding of compliance-heavy sectors and their ability to offer clear, practical legal advice without overcomplicating the process."
Guy Raven
Head of Surveillance Advisory, Westpac"Hannah demonstrated exceptional leadership and regulatory expertise. She played a pivotal role in developing the control room and establishing a strong regulatory compliance framework... Beyond her deep technical knowledge, Hannah is an outstanding mentor, approachable, and insightful."
Antonella Spatola
Founder, True To You Charity"Hannah at Click Legal has supported the board in establishing our documentation and legal framework to start on a solid footing. We appreciate her authentic interest in the charity's mission... We appreciate how she explains complex concepts in simple terms, avoiding legal jargon."
Sharon Yang
Head of Investment & Capital Mgmt"Hannah and Click Legal have provided reliable legal advice to us. It has been integral in helping us meet all our AFSL obligations with confidence. I highly recommend their services to any business needing compliance support."
Jason Watts GAICD
Managing Director, Neu Capital"Hannah blends rare regulatory expertise with sharp business acumen. As her Manager at Barclays, I watched her master APRA/ASIC frameworks and turn them into clear, actionable strategies... She's the kind of professional who simplifies complexity, and her integrity is unmatched."
Stuart Hill
Program Manager/Operations Manager"Hannah has exceptional depth of knowledge and expertise in building robust legal, risk, and compliance frameworks... Beyond her technical expertise, Hannah is a strategic thinker and a genuinely kind, friendly person who always supports and helps others."
Jason Lowry
Co-Founder, LPG"Could not recommend Click Legal more highly! Must have for start ups and small business owners looking to trust someone to help set up your business right!"
Jason Gold
Managing Director, IT Pro Tech"At IT Pro Tech, we partner with businesses who share our commitment to integrity. Click Legal stands out in the legal space for exactly that. Hannah and the team impressed us with their deep understanding of compliance-heavy sectors and their ability to offer clear, practical legal advice without overcomplicating the process."
Guy Raven
Head of Surveillance Advisory, Westpac"Hannah demonstrated exceptional leadership and regulatory expertise. She played a pivotal role in developing the control room and establishing a strong regulatory compliance framework... Beyond her deep technical knowledge, Hannah is an outstanding mentor, approachable, and insightful."
Antonella Spatola
Founder, True To You Charity"Hannah at Click Legal has supported the board in establishing our documentation and legal framework to start on a solid footing. We appreciate her authentic interest in the charity's mission... We appreciate how she explains complex concepts in simple terms, avoiding legal jargon."
Sharon Yang
Head of Investment & Capital Mgmt"Hannah and Click Legal have provided reliable legal advice to us. It has been integral in helping us meet all our AFSL obligations with confidence. I highly recommend their services to any business needing compliance support."
Jason Watts GAICD
Managing Director, Neu Capital"Hannah blends rare regulatory expertise with sharp business acumen. As her Manager at Barclays, I watched her master APRA/ASIC frameworks and turn them into clear, actionable strategies... She's the kind of professional who simplifies complexity, and her integrity is unmatched."
Stuart Hill
Program Manager/Operations Manager"Hannah has exceptional depth of knowledge and expertise in building robust legal, risk, and compliance frameworks... Beyond her technical expertise, Hannah is a strategic thinker and a genuinely kind, friendly person who always supports and helps others."
Jason Lowry
Co-Founder, LPG"Could not recommend Click Legal more highly! Must have for start ups and small business owners looking to trust someone to help set up your business right!"
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