Eleven obligations
The list below is the AML/CTF Act obligation set that attaches to an enrolled accounting practice. They are not optional and apply equally to a sole-trader practice and a 50-staff firm.
- Enrol with AUSTRAC (within 28 days of first designated service)
- ML/TF risk assessment for the practice
- AML/CTF Program (Part A and Part B), signed by the principal
- Customer due diligence on every client engaged for a designated service
- Sanctions and PEP screening at intake plus ongoing cadence
- Ongoing CDD: monitor and re-verify on risk-based cadence
- SMR lodgement workflow (within 3 business days)
- TTR lodgement workflow (within 10 business days for A$10k+ cash)
- IFTI lodgement workflow (within 10 business days for cross-border)
- 7-year retention for customer, transaction and Program records
- Staff training for everyone exposed to designated services
Scope test first
Before working through the eleven obligations, run the scope test. Bookkeeping, tax returns, BAS and management-accounting work are typically outside scope. Company formation, nominee director services, trust setup, client-money management and certain structuring work bring the practice into scope.
If any service line is in scope, the whole practice enrols and the whole practice has a Program. The Program describes the boundary between designated and non-designated work.
Implementation tools
Caltury handles all eleven obligations directly. The Starter tier (A$99/mo plus GST) covers a sole practitioner, Practice (A$249) covers 2 to 5 person practices, Firm (A$499) covers 6 to 15. There is no feature gating between tiers; the price reflects user count and practice size.
Founding-10 program offers 50 percent off for three years for the first 10 paying customers across Caltury. Several slots are taken; details on the founding page.
Common questions
Is the checklist available as a printable PDF?
Yes. The full checklist is at the resources hub as a downloadable PDF, no credit card and no sales contact required.
What if my practice is 95 percent tax-return work?
Tax-return work is not a designated service. If the remaining 5 percent includes anything from the designated-service list (company formation, trust, nominee, client-money, structuring), the practice enrols. If the 5 percent is also non-designated work, the practice may not need to enrol at all.
Can I share the checklist with my professional body or compliance committee?
Yes. The PDF is yours to distribute internally. The content is plain-English and does not assume prior AML/CTF knowledge.
What is the cost of doing nothing?
Civil penalties under the AML/CTF Act run into the millions per contravention. The realistic risk for a small practice is not the maximum; it is being non-enrolled when AUSTRAC writes to ask for the Program. The cost of starting in time is small. The cost of starting late is large.
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.