Enterprise DNA

Instead of First AML

Stop renting First AML. Own your AML compliance system.

We build your version around your offices, your risk method and the Act you report under, bring your First AML cases across and run it for you. Identity checks stay with the provider you choose; the files, the decisions and the deadlines become yours.

First AML prices every plan on application: an annual platform fee, units for each client onboarded, overage once those run out, and a one-off implementation fee.

Get your version built See it working
  • check_circleYour data in a database you own
  • check_circleOpen source, no lock-in
  • check_circleBuilt and run by Enterprise DNA

What the subscription charges for

Paying by the client for a register you must keep for years

First AML is sold as one platform for identity checks, company structures, screening and case management. The checks are a real cost wherever you buy them. The register around them, with its files, ratings, decisions and dates, is a short list of records that your firm has to keep for five or seven years anyway.

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A quote, not a price list

Launch, Optimise and Transform are all priced on application, and the price changes by country. You find out your bill after a sales call.

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Units for every client you take on

Contracts include a set of units, fixed units and pay-as-you-go overage once they run out. A busy year of new clients costs more.

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An implementation fee

A one-off charge to get onto the platform, on top of the yearly platform fee.

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The dashboards they chose to build

Reporting shows the views the platform offers. Which fee earner opens matters before identity is done, or how long reports take from first doubt to lodging, depends on what was built.

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The annual report as a separate exercise

Every year the same records have to become the DIA or AUSTRAC report. That is a reading of your own files, not a product feature.

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Years of client files in their cloud

DIA and AUSTRAC ask to see your due diligence records long after a client leaves. Today those records sit with a vendor you have to keep paying.

Your own AML desk

Start with the files and dates the Act sets

Onboarding

No matter opens before the file is done

Each client has one file: who they are, who owns or controls them, their risk, the checks on file and who approved them.

  • check Matters opened before identity was verified raised first thing, with section 16 of the AML/CFT Act or section 28 of the AML/CTF Act beside it
  • check New Zealand trusts, high risk clients and foreign politically exposed people held to enhanced due diligence until source of wealth and senior sign-off are recorded
  • check Owners, controllers and trustees listed for every company and trust, with anyone unverified flagged
  • check A sanctions possible match blocks the file until someone records why it is cleared

Reports

Every report counted from the day you decided

When the compliance officer decides there are grounds to report, the clock starts and the due date shows on every list.

  • check 3 working days for a SAR in New Zealand, 5 for a law firm, skipping weekends and the holidays you record
  • check 3 business days for an SMR in Australia, and 24 hours for terrorism financing
  • check Cash of 10,000 or more starts the PTR or TTR clock the day it is received
  • check A confidential working note for the report, with a tipping off warning, and nothing in the client's own letters

The programme

Audit, review and annual report dates kept

The risk assessment, programme, audit or independent evaluation, officer report and annual report each carry their last date and their next.

  • check An audit every three years under section 59, or an independent evaluation every three years for AUSTRAC
  • check The annual report to DIA by 31 August and the AUSTRAC compliance report by 30 September, with the year's counts drafted
  • check The Australian compliance officer notified within 14 days of appointment, and late notices flagged
  • check Vetting and yearly training for everyone with AML duties

Your records

Kept as long as the law says, and no longer

Ongoing reviews come round by risk, and every ended client shows the day its file can go.

  • check Ongoing reviews every 12, 24 or 36 months by risk, set to your own programme
  • check Five years after the relationship ends in New Zealand, seven in Australia
  • check Which clients bring cash, and which countries your high risk clients come from
  • check A due diligence file per client and a programme pack per office, in your firm's brand, for the auditor

Make it yours

Design your own First AML replacement

Everything starts from the open-source base. Then it gets your name, the parts you run, your rules and your data from First AML. Try it here, and we build the real one.

2. What it runs

3. Make it fit

4. Your colour

Your business · your First AML replacement Your version
YB Your business

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Answered from your own database

Build my version

We build it from the open-source base, bring your First AML data across and run it for you.

What it looks like

Ask it like you would ask a colleague

Real answers from a fictional New Zealand law firm and accounting practice and two Australian firms new to Tranche 2. Your compliance officer asks the question and checks the records behind the answer.

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AML Compliance for Claude Code

Connected to your own database

What needs my attention across our offices today?

report overdue

Entity
HSL
Ref
M-105
Detail
PTR for Rangi Construction Ltd
Due on
2026-10-09

report overdue

Entity
HSL
Ref
K-001
Detail
SAR for Rangi Construction Ltd
Due on
2026-10-20

report due

Entity
BCV
Ref
K-005
Detail
SMR for Ibrahim Haddad
Due on
2026-10-28

report due

Entity
BCV
Ref
M-301
Detail
TTR for Hayes Property Pty Ltd
Due on
2026-11-03

match to clear

Entity
HSL
Ref
C-1003
Detail
sanctions possible match (Screening provider)
Due on
2026-09-28

concern to decide

Entity
KAC
Ref
K-002
Detail
Bay Orchards Partnership: Large payment to an overseas account not linked to the orcha
Due on
2026-10-11

service before CDD

Entity
HSL
Ref
C-1004
Detail
M-104 opened 2026-10-13 before identity was verified (still not verified)

enhanced CDD gap

Entity
HSL
Ref
C-1002
Detail
Walker Family Trust is a trust on standard CDD. Trusts need enhanced CDD.

enhanced CDD gap

Entity
HSL
Ref
C-1003
Detail
Dmitri Volkov is a foreign PEP: no senior manager approval, source of wealth not verified

enhanced CDD gap

Entity
HSL
Ref
C-1005
Detail
Rangi Construction Ltd is rated high risk: no source of wealth or funds recorded

programme overdue

Entity
HSL
Ref
HSL
Detail
audit
Due on
2026-04-02

programme overdue

Entity
WTA
Ref
WTA
Detail
programme review
Due on
2026-07-15

programme overdue

Entity
WTA
Ref
WTA
Detail
risk assessment
Due on
2026-07-15

programme overdue

Entity
KAC
Ref
KAC
Detail
annual report 2025-26
Due on
2026-08-31

programme overdue

Entity
HSL
Ref
HSL
Detail
risk assessment
Due on
2026-09-18

review overdue

Entity
HSL
Ref
C-1007
Detail
Sophie Tan (low)
Due on
2026-09-13

onboarding stalled

Entity
HSL
Ref
C-1004
Detail
Lena Fischer onboarding since 2026-09-23
Due on
2026-09-23

Ask it anything

Questions answered from your AML register

These examples read across every office and every client at once. They are not a claim that First AML cannot produce a similar report.

chat_bubble How many customers sit at each risk rating, by firm?
chat_bubble How long does onboarding take, from first contact to identity verified?
chat_bubble Which customers are on enhanced CDD, and why?
chat_bubble Which matters started before the customer was verified?
chat_bubble Which customers bring the most cash?
chat_bubble How many concerns were raised, and how many became a report?
chat_bubble How many days from noticing something to lodging the report?
chat_bubble Which staff with AML duties are untrained or unvetted?
chat_bubble Which countries do our customers come from, and at what risk?
chat_bubble Which records can we lawfully dispose of this year?

Switching

How to switch from First AML

A move like this involves exporting your case list and reports, mapping your records, checking the results and keeping both systems available briefly while your team compares them.

  1. 1

    Export your records

    First AML's case list and regulatory reports download as CSV. Export the case list with each client's type, office, status, risk rating, PEP and sanctions result, and First AML case number. Export the regulatory reports you need too. Save case report PDFs with the client file, because identity documents, biometric results and company structure maps stay in those PDFs.

  2. 2

    Test the case-list import

    Load the case-list CSV into the new register, starting with a test run before you load records. The test run lets you review how the headings map. First AML report headings can differ, so check the mapping before you continue. The import is all or nothing and safe to repeat.

  3. 3

    Review the import results

    Read the test-run results and check the field mapping and any issues it reports before loading the records. Once the case list is in the register, check the records against the applicable AML rules. Review each finding and its cited rule, then correct the underlying record or decide what your compliance officer needs to address.

  4. 4

    Run both systems briefly

    For a short period, keep First AML available while your team also works from the new register. Compare live customer files, statuses, ratings, PEP and sanctions results, and upcoming reviews or reports in both systems. Keep using your existing identity-check provider. Record any differences and settle them before treating the new register as your working record.

  5. 5

    Switch off First AML

    Before ending First AML, confirm you have saved the case-report PDFs and any CSV reports you need with the client files. Make sure your team has checked the records it needs in the new register and knows how to use it through Claude Code. Then end your First AML service when you are ready to use the new register on its own.

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Where the real effort goes

The real work is usually mapping your own fields and rules, then deciding how much history to bring across. The case-list import does not bring identity documents, biometric results or structure maps, so keep those PDFs with the client files. If you have Enterprise DNA install and run it, they handle this mapping and migration work after reviewing your setup, offices and last annual report.

Not ready for a call?

Get your First AML switch plan by email

We will send you the step-by-step plan for moving your business off First AML, what the move really involves, and how we would do it for you.

One email with your plan. No spam, and you can unsubscribe any time.

Three ways to make it yours

Start with the free AML register or have your version built

Open source

Do it yourself

Free code

  1. 1 Clone the repo and run npm install, npm test and npm run demo.
  2. 2 Open it in Claude Code, Codex, OpenCode or Cursor.
  3. 3 Download your First AML case list as CSV and import it with a dry run first.
  4. 4 Set up your offices, compliance officer and holidays, then run /attention and /compliance every morning.
Get it on GitHub

Built around your business

We customise it

One setup fee, then a retainer

  • check Your risk method, client types and review cycles built in
  • check Your request letters, due diligence files and programme pack in your brand
  • check Your First AML cases brought across, offices and ratings mapped
  • check A client upload page, your check provider connected, or a screen for your team, if you want one

Omni by Enterprise DNA

We run it for you

One setup fee, then a retainer

  • check Installed and operated through Omni by Enterprise DNA
  • check Every fee earner can check a file, while only the compliance officer sees concerns and reports
  • check Late reports, open matches and files opened before identity raised every morning
  • check Rules kept current as DIA, AUSTRAC and the Acts change them
Book a call with Sam

Questions

Instead of First AML, answered

Does this replace the identity checks First AML runs? expand_more

No. Electronic identity verification, biometric checks and screening against PEP and sanctions lists need a data provider, and you keep paying one per check whichever system you use. Your version records each result, who checked it and how a possible match was cleared. We connect the provider you choose, or keep the one you have. What you stop renting is the register: the files, the ratings, the decisions and the dates.

Can we trust the deadlines and rules? expand_more

Each one is written down with its source: the AML/CFT Act 2009 and DIA guidance in New Zealand, including the 5 working day SAR deadline for law firms since November 2025, and the AML/CTF Act 2006 as amended in 2024 with AUSTRAC's reform guidance in Australia. Your team sees the section beside every finding. It is a records check, not legal advice; your programme and your compliance officer still decide.

What happens to the cases we already hold in First AML? expand_more

Your case list comes across from the CSV download, with each client's type, office, status, risk rating, PEP and sanctions result, and the First AML case number kept against the record. Identity documents, biometric results and structure maps stay in the case report PDFs, which you keep with the client file. Owners and controllers are added as each live client is reviewed.

We are new to Tranche 2. Is this enough to start? expand_more

It holds what AUSTRAC expects you to be able to show: enrolment and the compliance officer with the date AUSTRAC was told, the risk assessment and program dates, customer due diligence on every client, reports and their deadlines, training, and the compliance report each September. Published tools for Australian firms run to $999 a month at easyAML's top plan and from $667 a month for EngageAML Pro, before checks. Your version is a one-off build plus a retainer, with no charge per client onboarded.

What do we pay Enterprise DNA? expand_more

The code is free. A version built and run for your firm has one setup fee, then a retainer, with no charge per user or per client. Sam reviews your current setup, your offices and your last annual report before agreeing the scope.

Own the records behind every client you take on

Take 30 minutes with Sam to go through your First AML setup, your offices and your last annual report. We map how your firm onboards and reports, and agree what your version needs before you change systems.

Book a 30-minute call with Sam Get the free version

AML Compliance for Claude Code is free and open source, published by Enterprise DNA.

Done paying for First AML?

Get your version built