AML/CTF Compliance Costs: DIY vs Consultant vs Software Compared

One of the first questions every business asks when facing Tranche 2 is: "How much is this going to cost?" The answer depends on the approach you take. This article compares the real costs of AML/CTF compliance across five options — from doing nothing to using purpose-built software — so you can make an informed decision.

Option 0: Doing Nothing

Let's start with the option that some businesses are still considering: ignoring the requirements entirely.

Cost: Up to $33.3 million per breach.

Under the AML/CTF Act, civil penalties for non-compliance can reach $33.3 million for a body corporate per contravention. Even for individuals, penalties run into hundreds of thousands of dollars. AUSTRAC has demonstrated that it is willing to pursue enforcement — CBA was fined $700 million in 2018 for systemic AML/CTF failures, and Westpac settled for $1.3 billion in 2020.

Tranche 2 businesses will not face fines on that scale immediately, but AUSTRAC has made clear that wilful non-compliance will attract enforcement action. Beyond financial penalties, there is the reputational damage, potential loss of professional licences, and personal liability for directors and compliance officers.

Bottom line: Doing nothing is not a viable option.

Option 1: DIY with Templates

Some businesses attempt to build their AML/CTF program using free or low-cost templates downloaded from the internet or adapted from AUSTRAC's guidance materials.

Cost: $0–$500 for templates, plus significant time investment.

Pros

• Lowest upfront financial cost
• Full control over the content
• Can be tailored precisely to your business

Cons

• Requires deep understanding of the AML/CTF Act and AUSTRAC rules
• Time-intensive: expect 40–80+ hours for a small practice to develop a compliant program from scratch
• High risk of gaps — templates may not cover your specific designated services or risk profile
• No ongoing support or updates when regulations change
• No CDD workflow, training management, or record-keeping system
• If AUSTRAC reviews your program and finds it deficient, you bear all responsibility

Best for: Businesses with in-house legal or compliance expertise who need minimal external support.

Option 2: Sophie Grace AML/CTF Kit

Sophie Grace offers a pre-built AML/CTF compliance kit specifically designed for Tranche 2 businesses. The kit includes a Part A and Part B program template, risk assessment template, CDD forms, and guidance notes.

Cost: $8,800 (one-off).

Pros

• Professionally drafted by AML/CTF specialists
• Covers core program requirements
• Faster than building from scratch

Cons

• One-off purchase with no ongoing updates included
• Static documents — you must manually update them when regulations change
• No software platform for managing CDD, training, or record-keeping
• Still requires significant internal effort to customise, implement, and maintain
• No SMR lodgement support or ongoing monitoring tools

Best for: Businesses that want a solid starting point and have the internal capacity to manage ongoing compliance manually.

Option 3: Hiring a Consultant

Engaging an AML/CTF consultant to build your program, conduct your risk assessment, and advise on implementation is the premium option.

Cost: $5,000–$20,000+ depending on scope, firm size, and complexity.

Pros

• Expert advice tailored to your specific business
• Comprehensive risk assessment and program development
• Can include staff training delivery
• Provides a level of assurance that your program is fit for purpose
• Some consultants offer ongoing retainer arrangements

Cons

• Expensive, particularly for small businesses and sole practitioners
• Quality varies significantly between consultants
• Once the engagement ends, you are responsible for maintaining the program
• Consultants do not typically provide software or tools for ongoing CDD management
• Updating the program when regulations change often requires another engagement

Best for: Larger practices with complex risk profiles, or businesses that need external validation of their compliance approach.

Option 4: easyAML (Software)

easyAML is one of the dedicated AML/CTF compliance software platforms targeting Tranche 2 businesses.

Cost: $179–$999/month depending on plan and business size.

Pros

• Software-based platform with CDD workflows
• Includes program generation and risk assessment tools
• Ongoing updates as regulations change
• Cloud-based with record-keeping and document management

Cons

• Monthly cost adds up — $2,148 to $11,988 per year
• Higher tiers needed for larger teams or advanced features
• May include functionality you do not need
• Vendor lock-in: your compliance data sits in their platform

Best for: Businesses that want a comprehensive software solution and are willing to invest in a monthly subscription.

Option 5: ComplyReady (Software)

ComplyReady is purpose-built for Tranche 2 businesses — real estate agents, accountants, lawyers, and conveyancers — with a focus on simplicity, affordability, and practical compliance.

Cost: $99–$199/month depending on plan.

Pros

• All core compliance features: program generation, risk assessment, CDD workflows, training management, record-keeping, and SMR support
• Designed specifically for Tranche 2 designated services
• Significantly more affordable than competitors — $1,188 to $2,388 per year
• Intuitive interface that does not require AML/CTF expertise to use
• Ongoing updates included as regulations evolve
• Guided workflows that walk you through each obligation step by step
• Audit-ready documentation generated automatically

Cons

• Newer platform (though built by experienced AML/CTF professionals)
• May not suit very large or highly complex organisations that need bespoke solutions

Best for: Small to mid-sized practices that want an affordable, easy-to-use platform covering all Tranche 2 obligations.

Cost Comparison Summary

| Option | Upfront Cost | Annual Cost | Ongoing Support | CDD Tools | Program Updates | |--------|-------------|-------------|-----------------|-----------|-----------------| | Do nothing | $0 | $0 (until fined) | No | No | No | | DIY templates | $0–$500 | Your time | No | No | No | | Sophie Grace kit | $8,800 | Your time | No | No | Manual | | Consultant | $5,000–$20,000 | Retainer ($$$) | Varies | No | Per engagement | | easyAML | $0 | $2,148–$11,988 | Yes | Yes | Yes | | ComplyReady | $0 | $1,188–$2,388 | Yes | Yes | Yes |

The Right Choice Depends on Your Business

There is no single right answer. A large accounting firm with complex clients may benefit from a consultant engagement combined with software. A sole-practitioner conveyancer may find that ComplyReady alone covers everything they need.

What matters is that you do something before 1 July 2026. The cost of compliance is a fraction of the cost of non-compliance.

Start your free trial with ComplyReady and see which plan fits your practice.