AustracCheck is a workspace tool; your agency owns every compliance decision. This checklist is the sequence most agencies follow. Use it as a planning artefact — each item lists what AustracCheck covers and what stays with you.
1. Confirm you are captured
If you provide a designated service (brokering, selling, or transferring an interest in real property) with a geographical link to Australia, you are captured. Buyer's agents and property developers are captured under the same Tranche 2 amendments.
2. Enrol with AUSTRAC
Enrolment opens 31 March 2026 via AUSTRAC Online. Your agency lodges this directly. AustracCheck does not lodge on your behalf, but the platform tracks status and the enrolment-number record.
3. Adopt a written AML/CTF program
Part A is your risk-based framework. Part B sets out how you identify and verify customers. The program must be approved by the principal and reviewed periodically. AustracCheck generates a tailored draft from your onboarding questionnaire; the principal owns adoption and review.
4. Risk-rate your customer types and channels
Classify customers (individual, company, trust, foreign buyer, PEP) and channels (in-person, online, agent-introduced). Higher-risk combinations get enhanced due diligence. AustracCheck ships defaults; you tune them for your agency mix.
5. Build the customer due diligence workflow
Every captured deal: identify each party, verify identity to the program's standard, capture beneficial ownership for companies and trusts, and document the decision. AustracCheck runs this per customer.
6. Screen against sanctions and PEP lists
DFAT consolidated sanctions list and UN sanctions list are mandatory. PEP screening is a risk-based component. AustracCheck runs daily list refreshes; the platform flags hits, your agency decides next steps.
7. Set up reporting workflows
Threshold Transaction Reports (TTR) for cash or cash-equivalent transactions $10,000 AUD and over; Suspicious Matter Reports (SMR) when you form a suspicion. AustracCheck generates AUSTRAC-format drafts; your agency lodges via AUSTRAC Online.
8. Train your staff
Annual training, role-specific. Sales agents, property managers, principals, admin staff. AustracCheck's Training Center ships modules and per-staff completion certificates the audit log retains.
9. Set seven-year record retention
Customer files, transaction records, sanctions screening results, training certificates, and program-amendment history all need seven-year retention. AustracCheck's audit log keeps every action timestamped and exportable.
10. Schedule the independent review
The Act requires periodic independent review of the AML/CTF program. AustracCheck does not perform reviews; you engage an external reviewer (lawyer, compliance specialist) and store their report against the program record.