The eleven obligations in order
There are eleven obligations under the AML/CTF Act that attach to a Tranche 2 reporting entity. They are not optional, they do not scale with practice size, and they all apply from the same date. The list below covers each one in the order most small practices will tackle them.
- 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 buyer and vendor
- 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
Suggested implementation timeline
Working back from 1 July 2026, a defensible timeline runs roughly: complete the readiness check by end of Q1 2026, decide build / buy / hire by end-March, sign up for Caltury and start setup in April, generate the Program in May, lodge enrolment in mid-June, complete staff training in late June, go live on 1 July.
Practices starting late can compress this to a fortnight using the Caltury 14-day trial, but Foreign-buyer-heavy practices should leave at least three weeks because the customer-form configuration takes longer to tune.
Which obligations Caltury handles for you
Caltury handles 1, 2, 3, 4, 5, 6, 7, 8, 9, 10 and 11 directly. That is the whole list. Enrolment is prepared in the wizard, risk assessment is generated, Program is built, CDD workflow is live, screening runs at intake and on cadence, ongoing CDD is scheduled, SMR / TTR / IFTI drafts are produced in AUSTRAC format, retention vault runs for 7 years, training module is built in.
The single thing Caltury does not do is lodge AUSTRAC reports for you. AUSTRAC Online is the lodgement channel and accepts only your practice's own submission. Caltury produces the draft; you review, sign and lodge.
Common questions
Is there a free version of this checklist as a PDF?
Yes. The full checklist is available at the resources hub as a downloadable PDF. No credit card, no sales call, just an email address.
Does completing the checklist guarantee compliance?
Compliance is an ongoing state, not a one-off checklist. Having the eleven items in place by 1 July 2026 satisfies the obligation set as it stands on that date. Maintaining them through inspections, staff turnover and changes in the practice's risk profile is the ongoing work.
What if my practice is too small for all of this?
The obligations apply regardless of size. The implementation can be smaller (one named Compliance Officer, fewer customer files, shorter training cohort) but the obligation set cannot be scaled down. Caltury's Starter tier is built for the sole practitioner doing 30 to 50 settlements a year.
Can I use the checklist before signing up to Caltury?
Yes. The checklist is free and does not require any commitment. It is most useful before signing up because it makes the readiness conversation concrete.
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.