Part A for an accounting practice
Part A documents the practice's ML/TF risk assessment (covering customer types, services provided, channels, geographies), the systems and controls in place (CDD, ongoing monitoring, sanctions screening, reporting), the named Compliance Officer and their authority, staff training arrangements, and the procedure for independent review.
For an accounting practice the risk assessment typically emphasises the designated services the practice actually provides (rather than the full Act-defined set), the customer cohorts that receive those services, and the channels through which capital flows on behalf of clients. A practice doing trust formation has a very different Part A than a practice doing only management-accounting work for SMEs that happens to include some company formations.
Part B for an accounting practice
Part B sets out how the practice identifies individuals, companies and trusts at engagement, captures beneficial ownership for company and trust customers, and re-verifies on the risk-based cadence. For an accounting practice the beneficial-ownership section is usually the deepest part because designated services frequently involve structuring with multiple ownership layers.
Caltury's Part B ties directly into the customer onboarding workflow used in the application. The document and the workflow stay in sync because the workflow is generated from the same source as the document.
Generation, signature and review
Caltury's Program builder produces Part A and Part B as a single document tailored to your practice. You review and sign as the named Compliance Officer. The Program is regenerated whenever the practice's risk profile or service mix changes. Old versions are retained in the audit log; current version is exportable on demand for any AUSTRAC enquiry.
Independent review is required at least every three years under the Act. For a small practice the reviewer is typically an external auditor, an AML consultant, or a peer-practice principal. Caltury supports the independent review by exporting the Program, the customer records, the screening history and the audit log for the reviewer to assess.
Common questions
Do all designated services need to be covered in the Program?
Yes. The Program describes how each designated service the practice provides is handled under the AML/CTF framework. Services the practice does not provide do not need to be covered.
Is there a standard Program length?
No. AUSTRAC does not prescribe length. Caltury's generated Programs typically run 25 to 40 pages for a small accounting practice depending on the breadth of services covered. Length is not the measure of quality; specificity to the practice is.
Can a CPA Australia or CA ANZ template substitute for a Program?
Professional-body templates can be a useful starting point, but the obligation is to maintain the practice's own Program, signed by the named Compliance Officer, reflecting the practice's actual procedures. A template without that customisation is unlikely to satisfy an inspection.
What happens if a service line is added after the Program is signed?
The Program is regenerated to cover the new service line and re-signed. Caltury supports this without losing the previous version, which is retained in the audit log.
This page is general information about Australian AML/CTF obligations. It is not legal advice. AUSTRAC has not reviewed this content. For situations specific to your practice consult an Australian-qualified lawyer or AML/CTF adviser.