AML/CTF

AML Compliance Levy: A Pricing Guide for Accounting Firms  

There is a moment many firm owners are quietly dreading.

It is not the CDD checklist. It is not the software. It is not even the extra compliance work.

It is the client asking, “Why am I being charged for this?”

That is why AML pricing for accountants has become such a live issue. Accounting firms know AML/CTF Tranche 2 creates real work, but many are still unsure how to price it clearly, confidently, and fairly.

So, they hesitate.

They absorb a little time here. They discount a fee there. They tell themselves it will not be too bad.

Then the margin disappears.

AML/CTF work has a real cost

The first mindset shift is simple. 

AML/CTF compliance is not “a bit of admin”. It is professional risk work. 

Before your firm provides a designated service, someone may need to check the scope, collect documents, verify identities, map beneficial ownership, complete screening, assess risk, and record the client's acceptance decision. 

After that, the work continues. 

Client relationships need monitoring. Risk ratings may need refreshing. Ownership or control changes need to be reviewed. New entities, restructures, or major transactions can trigger more work. 

None of that happens by magic. 

It takes staff time, partner oversight, software, training, and record keeping. If the client does not pay for it, the firm does. 

That is not sustainable practice management. 

Why firms undercharge AML/CTF work

Most undercharging does not happen because partners cannot do the maths.

It happens because the conversation feels uncomfortable.

A long-standing client has never seen an AML onboarding fee before. A small business owner may not understand why customer due diligence fees apply to them. A family group may question why the firm now needs ownership and control information when the relationship has existed for years.

So, the partner softens.

“We will just include it this year.”
“We will absorb it for this client.”
“We do not want to upset them.”

I understand that instinct. We are in a relationship business. Good accountants care about their clients and do not want to sound like they are creating another charge for the sake of it.

But there is a difference between empathy and underpricing.

Empathy explains the fee clearly.

Underpricing hides the cost until the firm carries it. 

Start with one simple benchmark

A useful starting point for many smaller firms is this:

Price AML/CTF work at around one to three hours at the relevant charge-out rate, adjusted for client complexity.

A simple client may sit closer to one hour.

A trust, SMSF or small company group may sit closer to two.

A complex group, offshore connection, transaction client or higher-risk matter may need three hours or more.

This benchmark gives you a practical anchor. It also helps your team stop treating AML fees as a guess.

The question is not, “What will clients tolerate?” The better question is, “What does this work genuinely cost us to perform properly?”

Once you know that, your AML/CTF pricing becomes much easier to defend. 

Do not use one vague fee for everything

A single catch-all fee sounds simple, but it often creates confusion.

Some AML/CTF work happens at the start of the relationship. Some of it happens every year. Some only happens when the client’s circumstances change.

Those are different types of work. They should be priced differently.

A clearer model separates AML fees for accounting firms into three categories:

1. AML onboarding fee
2. Annual AML compliance levy
3. Event-triggered AML review fees

That structure is easier for clients to understand. It is also easier for your team to apply consistently.

1. AML Onboarding Fee

The AML onboarding fee covers the initial compliance work required before the engagement starts.

This may include:

• Customer due diligence
• Identity verification
• Beneficial ownership checks
• PEP, sanctions and adverse media screening
• Risk rating
• Client acceptance documentation

This is usually the heaviest compliance lift in the client lifecycle. The firm is setting up the record, confirming who it is dealing with and documenting the decision to proceed.

Indicative AML onboarding fee ranges may look like this:

• Individual or sole trader: $195 to $450
• Simple company: $250 to $550
• Trust with corporate trustee: $350 to $750
• Multi-entity group: $500 to $1,100
• Complex group: $750 to $2,000 plus

These are not universal rules. Your firm should adjust them based on internal costs, software, workflow, and client mix.

The important point is that the fee is not hidden.

You might describe it this way:

“Our engagement includes an AML/CTF Compliance Onboarding Fee of $X. This covers the identity verification, beneficial ownership documentation, screening and risk assessment required before we commence this engagement.”

That is clear, calm, and professional.

No apology is required.

2. Annual AML Compliance Levy

The AML compliance levy is the recurring fee that funds ongoing monitoring.

This is where many firms undercharge.

They do the onboarding work once, then forget that AML/CTF obligations continue across the client relationship. Monitoring still needs time. Files still need updating. Screening may need refreshing. Risk changes need to be considered.

Indicative annual AML compliance levy ranges may include:

• Low-risk client group: $150 to $250 per year
• Medium-risk client group: $250 to $450 per year
• High-risk client group: $450 to $900 plus per year

This should be included in your annual engagement letter or renewal.

A simple explanation works best:

“Our engagement includes an annual AML/CTF Compliance Levy of $X. This covers ongoing monitoring, screening refreshes, risk rating reviews and compliance record maintenance required for relevant engagements.”

Do not over-explain it.

When a fee is legitimate, the explanation does not need to sound defensive.

3. Event-Triggered AML Fees

Some AML/CTF work only arises when something changes.

A new director. A trustee change. A new company. A restructure. An overseas beneficial owner. A business sale. An LRBA. A source of funds question.

Those events create extra work. They should not be absorbed into the annual levy unless you have deliberately priced them into a broader package.

Indicative event-triggered AML fees may include:

• Director, shareholder, trustee or appointor change: $195 to $350
• New entity added to a group: $350 to $750
• New overseas beneficial owner or controller: $450 to $950
• Major transaction review: $750 to $2,500 plus
• Source of funds review: $500 to $1,500 plus

The key is advance notice.

Put the event fees in the engagement letter before the issue arises. Clients are far more likely to accept a fee when they were told about the trigger upfront.

Surprise invoices damage trust. Clear terms protect it. 

Build the fee around complexity

Not every client should carry the same AML/CTF pricing.

A sole trader with a simple local business does not create the same compliance workload as a multi-entity family group with trusts, companies, related parties and overseas connections.

If you charge the same amount to both, one of two things happens.

You overcharge the simple client, or you undercharge the complex one.

Neither is a good outcome.

A better approach is to tier your AML/CTF pricing by risk and complexity. For example:

• Simple individual or sole trader
• Simple company
• Trust or SMSF
• Multi-entity group
• Complex or higher-risk structure
• Transaction or advisory client

This helps partners apply the model fairly. It also gives staff a clearer explanation when clients ask why different fees apply.

The answer is straightforward.

The fee reflects the work required. 

Do not make the fee feel optional

This is where firms often weaken their own position.

A partner introduces the AML fee, the client pushes back, and the firm immediately offers to waive it “just this once”.

I understand the instinct. We all want to preserve relationships.

But the moment you waive the fee too easily, you teach the client that the fee was optional. Worse, you may teach your team the same thing.

A better response is:

“I understand the question. The work still needs to be completed whether we charge for it separately or absorb it internally. We have chosen to show the AML/CTF fee clearly because it reflects real compliance work attached to the engagement.”

That is enough.

You are not asking permission to run your firm properly. 

Price the work, then perform it

There is one important warning.

Do not charge AML fees unless the work is actually performed.

Every AML onboarding fee, annual compliance levy or event-triggered fee should connect to a completed piece of work. That may be a CDD record, screening result, beneficial ownership summary, risk rating, or monitoring review.

This protects your firm commercially and professionally.

AML/CTF pricing should never become a loose surcharge. It should be tied to real work, performed properly, and supported by your internal process.

That is how pricing becomes defensible. 

Why this matters for smaller firms

For 1 to 5 partner firms, this issue is especially important.

Large firms may be able to absorb inefficiency for longer. Smaller firms usually cannot.

If a sole practitioner spends unpaid evenings chasing CDD documents, that cost is personal.

If a small partnership absorbs monitoring time across hundreds of clients, that cost comes straight out of partner profit.

If managers are doing compliance work that was never priced, that cost appears later as write-offs, stress and capacity pressure.

AML/CTF compliance is not just a regulatory issue. It is a margin issue.

And margin discipline is not greed. It is what allows a firm to keep serving clients well.

Make the pricing visible in the engagement letter

Your AML/CTF pricing model should not live in a partner’s head.

It needs to appear in the engagement letter.

That does three useful things.

First, it sets expectations early.

Second, it gives your team a clear reference point.

Third, it reduces the chance of awkward fee conversations after the work has already started.

At minimum, your engagement letter should explain:

• the AML onboarding fee
• the annual AML compliance levy
• when event-triggered fees may apply
• the client’s obligation to provide information
• the firm’s right to pause work if required information is not provided

This is not about making the engagement letter heavy. It is about making commercial terms clear.

A client may still ask questions. That is fine. Questions are easier to handle when the firm has already explained the standard in writing. 

The practical decision

Your firm has three choices.

You can absorb AML/CTF costs silently.
You can hide them inside general fee increases.
Or you can price the work clearly, explain it professionally, and perform it consistently.

The third option is the strongest.

It gives clients transparency. It gives your team confidence. It gives partners a commercial model that does not punish the firm for doing compliance properly.

The aim is not to overcharge.

The aim is to stop pretending that regulated compliance work has no cost.

AML/CTF work is real professional work. Price it that way. 

This article is general guidance only and does not constitute legal advice. Firms should confirm their specific obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and seek independent legal advice where required.

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