Part A: systems and controls
Part A documents the practice's ML/TF risk assessment, the systems and controls used to manage risk (CDD, ongoing monitoring, sanctions screening, reporting workflows), the named Compliance Officer and their authority, staff training, and independent-review arrangements. For a conveyancing practice the risk assessment is normally relatively contained: customer types are predictable (buyers, vendors), geographies follow the settlement footprint, and capital flows follow the trust-account pattern.
Where the Part A gets denser is in the foreign-buyer and trust-buyer scenarios. Both require explicit risk-band logic in the Program, because both involve enhanced due diligence and IFTI reporting that the standard residential CDD path does not.
Part B: customer identification
Part B sets out how individuals, companies, trustees, and beneficiaries are identified at intake, how beneficial ownership is captured for company and trust customers, and the ongoing CDD cadence per risk band. For conveyancing the Part B is operationally critical because settlement-day timing is unforgiving; CDD that has not been completed by settlement is non-compliant CDD.
- Individual: name, DOB, address, photo ID, optional remote verification
- Company buyer: incorporation, beneficial owners >= 25%
- Trust buyer: trustee, settlor, beneficiaries
- Foreign buyer: enhanced due diligence, source-of-funds, source-of-wealth
- Cadence: high 6-monthly, medium yearly, low every 3 years
How Caltury produces and maintains the Program
Caltury's Program builder walks the practice through a structured questionnaire covering state, customer mix, transaction values, foreign-buyer exposure and staff arrangements. The output is a Part A and Part B document tailored to your practice and ready for signature by the practice principal.
The Program is regenerated whenever the practice's risk profile changes. Old versions sit in the audit log; the current version is exportable as PDF for any AUSTRAC enquiry. Independent review at least every three years is supported by exports of the Program, customer records, screening history and audit log.
Common questions
Is the Program reviewed by AUSTRAC at enrolment?
No. AUSTRAC does not review Programs at enrolment. The Program is what they ask for later in an inspection or written enquiry. The earlier the Program is in place, the safer the practice is.
Does the Program need to be a different document for each office?
No, where the offices operate under one legal entity. One Program covers all offices, with any office-specific risk indicators identified explicitly.
What if the practice principal is not technically literate enough to manage AML software?
Caltury is built specifically for non-technical operators. The Program builder is a structured questionnaire in plain English. No code, no complex configuration. If a sole-practitioner conveyancer can manage a PEXA workspace they can manage Caltury.
How long is a typical Conveyancing Program once generated?
Typically 30 to 45 pages depending on the breadth of services and the depth of risk-band logic in Part A. Length is not the measure of compliance; specificity to the practice is.
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.