For Practice Managers

Setting up AML/CTF compliance at your practice — AUSTRAC 2026 deadline guide

The compliance project has landed on your desk and the deadline is 1 July 2026. You do not need a compliance background — you need a structured process that gets a board-ready program built and approved before the partners ask what's happening.

Start FreeView Requirements

Compliance Challenges for Practice Managers

Practice managers at law firms, accounting practices, and real estate agencies must build a compliant AML/CTF program by 1 July 2026. AutoAML generates all 13 required documents and guides you through every step.

The project arrived without a playbook

Most practice managers were not trained in AML/CTF compliance. The obligation arrived via a legislative amendment, and the expectation is that you produce a 13-document compliance program, get it board-approved, and train the whole team — in time for a deadline that does not move.

The whole team needs training before July 1

Every staff member who deals with clients in a designated service must be trained under the firm's AML/CTF program. Organising, delivering, and documenting training across a busy practice — with high staff turnover — is a project within the project.

Partners need to sign off — and they'll ask hard questions

The compliance program requires board or principal endorsement under s 81. Partners who have never dealt with AUSTRAC will ask whether the program is actually compliant, what the penalties are for getting it wrong, and what the firm's audit exposure looks like.

Keeping the program current after go-live

Building the program for July 1 is the start, not the finish. AML/CTF Rules Chapter 15 requires reviews at least every three years, and any material change to the practice triggers an update obligation. Someone has to own this ongoing.

What Practice Managers Need for Compliance

The AML/CTF Act 2006 (Cth) and the AML/CTF Rules require all reporting entities to maintain these documents and procedures.

Complete AML/CTF Program (Part A and Part B) ready for board or partner sign-off — s 81
ML/TF Risk Assessment covering all practice areas and designated services
CDD procedures with step-by-step guidance for client-facing staff
SMR procedures with clear escalation pathways to the compliance officer — s 41
TTR procedures for applicable $10,000+ cash transactions — s 43
Record-keeping policies meeting the 7-year retention requirement — s 107
Staff training program with assessment, tracking, and completion evidence
Compliance officer appointment with a documented role description and reporting line

Deadline & Applicability

Practices providing designated services must have their complete AML/CTF program operational by 1 July 2026. This means the program is board-adopted, staff are trained, a compliance officer is formally appointed, and the practice is enrolled with AUSTRAC. AUSTRAC has indicated guided enrolment support from late 2025.

Last reviewed: · Information is general guidance, not legal advice.

How AutoAML Helps Practice Managers

AI-Generated Documents

Step-by-step guided setup walks you through the onboarding questionnaire. All 13 compliance documents are generated and formatted for board or partner review — not a template, but a draft built from your practice's actual services.

Team & Audit Trail

Generate training materials for your team, track who has completed training, and assign compliance roles — all with a clear audit trail that holds up to an AUSTRAC inspection.

Ongoing Compliance

Implementation checklist tracks your progress to July 1. Compliance calendar ensures nothing is missed after go-live — review dates, training refreshers, and annual report generation are all automated.

Frequently Asked Questions

Practice Managers & AUSTRAC: common questions

What does a compliant AML/CTF program need to contain?
Under s 81 of the AML/CTF Act 2006 (Cth), the program must have two parts. Part A covers the systems and controls side — appointing a compliance officer, employee due diligence, an ongoing training program, board oversight, and an independent review mechanism. Part B covers customer-facing obligations — Customer Due Diligence (CDD) procedures tailored to your customer types and services, enhanced CDD for high-risk situations, and beneficial-owner identification. The program must be documented, board-adopted, and kept current.
How long does it take to build a compliant AML/CTF program?
With a compliance consultant, the typical engagement is 6–12 weeks and $5,000–$25,000 in fees. With AutoAML, a draft of all 13 required documents tailored to your practice is generated in under 10 minutes from the onboarding questionnaire. You should then allow a few hours for the partners to review and adopt the program before the deadline.
What is the compliance officer's role in a professional practice?
The appointed compliance officer must have sufficient seniority to access the board, dedicated time to administer the program, and the authority to implement compliance decisions. In a law or accounting firm, this is often a senior partner or the managing partner. The role requires overseeing all SMR and TTR lodgements, managing the training program, maintaining the risk assessment, and reporting to the board at least annually on compliance status.
How do I get the partners or board to sign off on the compliance program?
Your AML/CTF program requires documented board or principal endorsement. AutoAML generates a board-ready executive summary alongside the detailed compliance documents — covering the firm's obligations, the key risks identified in the risk assessment, and the program's response to each. Having this formatted for non-compliance professionals makes sign-off significantly faster.
What if we add a new service line after July 2026?
If the new service is a designated service, you must update your AML/CTF program before commencing it. AML/CTF Rule 4.1.1 requires the program to reflect the reporting entity's current designated services and risk profile. A material change to the practice — new services, new delivery channels, significant change in customer base — triggers an update obligation. AutoAML sends a prompt to review documents when service details change.
Does each office in our firm need its own AML/CTF program?
If multiple offices operate under the same Australian Business Number and legal entity, one AML/CTF program can cover all offices, provided the program addresses the specific risk profile of each location. However, if offices operate as separate legal entities, each is a separate reporting entity and must have its own program, enrolment with AUSTRAC, and compliance officer.

Related compliance guides

Different roles in the same organisation often have overlapping but distinct AML/CTF responsibilities.

Compliance OfficersAppointed AML/CTF compliance officers at Tranche 2 firms must have a compliant program by 1 July 2026. Understand your s 81 obligations under the AML/CTF Act 2006 (Cth).Read guideAccounting FirmsThe AML/CTF Amendment Act 2024 brings accounting firms within the AML/CTF regime from 1 July 2026. Generate a compliant program for your firm and manage every client entity from one dashboard.Read guideAUSTRAC July 2026 Deadline1 July 2026 is the AUSTRAC Tranche 2 commencement date. No grace period. No extensions announced. This checklist covers exactly what accountants, lawyers, real estate agents, and conveyancers need before the deadline.Read guide

Build a board-ready program before the deadline

Built for Australian businesses navigating AUSTRAC Tranche 2. Free until 1 July 2026.

Start Your Free Compliance Program

Free until the 1 July 2026 AUSTRAC deadline. Cancel anytime.