What is the AMLHQ Hybrid Model?
The Hybrid Model is built for a specific post-July problem: agencies that committed to AML software investment before the final Tranche 2 guidance became clear now need real compliance governance without abandoning their platform.
Under the Hybrid Model, your agency keeps your existing AML/VOI platform (GreenID, Intellinetics, or equivalent) and adds an AMLHQ Compliance Officer to provide oversight, escalation, decision support and audit-ready documentation. It is a bridge: you retain your technology investment, you gain human compliance judgment, and you maintain a clear escalation path when risk increases.
The Problem the Hybrid Model Solves
AML software performs a critical function — it manages workflows, captures information, flags risks and maintains audit trails. But software cannot make compliance decisions. When a customer with multiple entities appears, when a PEP alert triggers, when an SMR deadline approaches, when staff training gaps emerge — those require human judgment, authority and accountability.
Many agencies bought software for workflow management and assumed it was "full compliance." Six weeks after 1 July, they realised it was not. The Hybrid Model is built for that realisation: keep the software that works, add the compliance officer that makes it defensible.
How the Hybrid Model Works
Your AML Platform (Stays as Is)
- Customer onboarding workflow
- Document collection and storage
- Transaction flagging and filtering
- Automated risk alerts
- Reporting reminders (SMR, TTR)
- Audit trail and record keeping
AMLHQ Compliance Officer Layer (Adds)
- Human escalation oversight
- Complex entity analysis
- Compliance decision authority
- SMR/TTR judgment and filing
- Staff training oversight
- Independent evaluation readiness
The Integration Flow
Platform performs initial assessment → Alert flags for human review → AMLHQ CO evaluates → Compliance decision made → Evidence documented → File closed or escalated → Audit trail complete.
Your platform handles volume and workflow. The Compliance Officer handles judgment. This separation is actually cleaner than forcing software to pretend it can do both.
Who Should Consider Hybrid?
- Agencies that locked into platform contracts: You invested in software and are committed until renewal. Hybrid lets you add compliance without rip-and-replace.
- Agencies unsure if current software is "enough": If you suspect your platform alone won't satisfy independent evaluation, Hybrid closes that gap.
- Multi-office groups using one platform: Central CO oversight can serve all offices without changing their individual workflows.
- Agencies wanting to defer SENTINEL migration: Hybrid keeps your current platform working while you evaluate full AMLHQ transition later.
- Compliance-confident agencies needing a lightweight governance layer: If your team is highly organised, Hybrid provides oversight without replacing your processes.
Hybrid Model Pricing & Structure
Monthly cost starts at: $350+ (+ GST). This depends on agency size and transaction volume.
This is lower than our CO and CFO models because your existing platform handles infrastructure, onboarding and workflow. AMLHQ provides the compliance layer only.
Cost Recovery Through Vendor Admin Fees
Like all AMLHQ models, Hybrid costs can be recovered through vendor administration fees disclosed in your agency agreements. For example: a $400 monthly compliance cost divided across 4 monthly settlements = $100 per transaction, added transparently to vendor admin fees.
This makes Hybrid potentially cost-neutral to your agency while ensuring your compliance framework is defensible. AMLHQ's certified Business Advisors can guide you through state-specific implementation.
What You Get: Hybrid Model Features
Named Compliance Officer
A qualified, accountable person responsible for your AML/CTF framework, escalation decisions and SMR/TTR management.
Escalation Portal
A simple interface for your staff to escalate files flagged by your platform for CO review and decision.
Complex Entity Analysis
CO review of trusts, companies, beneficial owners and international structures where your platform may flag risk but cannot make judgment calls.
SMR/TTR Support
Compliance Officer guidance on suspicious matter and threshold transaction decisions, filing obligations and timing.
Staff Training Oversight
CO coordination with your training program and competency assessment, with documented records.
Compliance Reporting
Monthly governance reporting showing escalation activity, red flags, training status and compliance trends across your agency.
Independent Evaluation Readiness
Your CO maintains the evidence and reasoning trail an independent evaluator will need — documented decisions, escalation rationale, staff records, and SMR/TTR management.
Email & Phone Support
Direct access to your assigned Compliance Officer for urgent escalations and compliance questions.
Hybrid vs Other AMLHQ Models
Hybrid Model
- Keep your existing AML/VOI platform
- Add AMLHQ Compliance Officer layer
- Lower cost (CO governance only)
- Faster deployment (no platform change)
- Ideal for: Platform-committed agencies
CO Model
- Migrate to SENTINEL platform
- Full integrated compliance workflow
- Higher cost (platform + CO)
- Complete framework
- Ideal for: Agencies seeking full refresh
Is Hybrid Right for Your Agency?
Hybrid is the right choice if:
- You are committed to your current AML platform for 12–24 months
- Your platform handles workflow and documentation well
- You are uncertain whether compliance officer oversight is missing
- You want to test AMLHQ CO capability before full platform migration
- You need compliance governance without significant operational change
CO Model might be better if:
- Your current platform is causing operational friction
- You want an integrated, purpose-built real estate AML platform
- You are considering technology refresh anyway
- You want full AI-assisted risk analysis built into your workflow
Next Steps
Ready to explore Hybrid? Email admin@amlhq.com.au with:
- Your current AML/VOI platform name
- Your agency size (number of offices, approx. monthly transactions)
- Key compliance concerns (escalation process, complex entities, SMR management, etc.)
We'll schedule a 20-minute call to confirm whether Hybrid is the right fit and discuss deployment timeline.