The eleven obligations
The list below is the AML/CTF Act obligation set that attaches to an enrolled agency. They are not optional, they do not scale with agency size, and they all apply from 1 July 2026.
- Enrol with AUSTRAC (within 28 days of first designated service)
- ML/TF risk assessment for the agency
- AML/CTF Program (Part A and Part B), signed by the licensee
- 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
Real-estate-specific implementation notes
Property management is not currently a designated service, so the obligation set attaches to the sales side only. For mixed-line agencies, the Program documents which staff and which workflows are in scope and which are not.
Foreign-buyer-heavy agencies (Gold Coast prestige, Sydney eastern suburbs, Melbourne inner-east, Brisbane CBD) should expect enhanced due diligence on a meaningful proportion of buyer-side files. Build the customer-form configuration for that pattern, not as an exception.
What Caltury handles end to end
Caltury handles all eleven obligations directly. Enrolment is prepared, Program is generated, customer onboarding is live, screening runs at intake and on cadence, ongoing CDD is scheduled, SMR / IFTI drafts are produced, retention vault runs for 7 years, training module is built in.
Lodgement of AUSTRAC reports remains with the agency (AUSTRAC Online accepts only the practice's own submission), but Caltury produces drafts in the correct format so review and lodgement takes 15 to 30 minutes per report.
Common questions
Does the checklist cover property managers?
Property management is not currently a designated service under the Act, so the obligations do not attach to property-management activity. Mixed agencies enrol on the sales side only. Tenants and landlords managed under a property-management agreement are not AML customers.
We are a buyer's advocate. Do we follow the same checklist?
Yes. Buyer's advocacy is assisting in the buying of real estate, which is a designated service. The obligation set is identical to a sales agency. The customer profile differs (you have buyers as customers, you may also need to capture vendor-side information for the transaction context) but the eleven obligations are the same.
Can sales agents do their own training?
Yes. Caltury's training module is designed to be completed by a sales agent in under an hour. Each agent's certificate is retained for the 7-year retention period. The Compliance Officer can see who has trained and when.
Is there a printable PDF version of the checklist?
Yes. The full checklist is at the resources hub as a downloadable PDF. No credit card, no sales call.
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.