Week-by-week AML prep countdown: 13 weeks to 1 July 2026
A week-by-week action plan for real estate agencies with roughly 13 weeks until AML/CTF obligations commence on 1 July 2026. What to do each week — in the right order.
Week-by-week AML prep countdown: 13 weeks to 1 July 2026
If you are reading this in early April 2026, you have roughly 13 weeks until AML/CTF obligations commence for real estate agencies. That is enough time to get compliant — but not if you treat it as a June problem.
This post gives you a week-by-week plan. Not month-by-month generalities — a specific task for each of the 13 weeks, in an order that builds on itself.
Why a countdown works better than a checklist
The six preparation obligations are not independent tasks you can complete in any order. Your risk assessment has to come before your program. Your program has to be approved before you train your staff on it. Your CDD process has to be tested before it goes live on 1 July.
Doing them in the wrong sequence wastes time. A week-by-week countdown forces the right order — and gives you a clear picture of where you are falling behind.
Weeks 13–11 — Foundation
- 1
Week 13 (1–6 April) — Enrol with AUSTRAC
Enrolment opened 31 March. Complete it now via AUSTRAC Online. You will need your ABN, business details, and compliance officer details (even if the appointment isn't finalised — you have until 29 July to notify AUSTRAC). The process takes 20–30 minutes. Do not defer this — enrolment is a legal requirement with a hard deadline.
- 2
Week 12 (7–13 April) — Download the AUSTRAC Program Starter Kit
AUSTRAC publishes a free Program Starter Kit specifically for agencies with 15 or fewer staff providing one designated service. Download it from the AUSTRAC website. Read the overview document before you do anything else — it maps the 19 obligations and explains how the templates connect. This is the foundation for everything that follows.
- 3
Week 11 (14–20 April) — Conduct your ML/TF/PF risk assessment
Before you write your program, you need a documented risk assessment. The Starter Kit includes a pre-populated template in Word format. Work through each section: your customers (who are they?), your services (what transactions do you facilitate?), your delivery channels (in-person, remote, or both?), and your geographic exposure (where do clients and their funds come from?). Rate the likelihood and impact of each risk category. Senior management sign-off is required — get that done this week.
Source: Preparation timeline suggested by AML Simple. Legislative dates from AML/CTF Amendment Act 2024.
Weeks 10–8 — Program development
- 4
Week 10 (21–27 April) — Draft your AML/CTF program (Part A)
Your risk assessment feeds directly into your program. Start with the governance and CDD sections — these are the most critical and take the most time to customise. Part A of the program covers the overall governance framework: roles, responsibilities, and how senior management oversees ML/TF/PF risk. Use the Starter Kit template as your base.
- 5
Week 9 (28 April–4 May) — Draft your AML/CTF program (Part B)
Part B covers your customer-facing obligations: customer due diligence, ongoing monitoring, enhanced due diligence triggers, and the identification and verification procedures your agents will follow. This is the section your staff will use day-to-day — make sure the procedures are practical, not just policy statements.
- 6
Week 8 (5–11 May) — Draft your AML/CTF program (Part C) and get sign-off
Part C covers reporting and record-keeping: how you will identify and file Suspicious Matter Reports (within 3 business days, or 24 hours for terrorism financing), how you will report cash transactions of A$10,000 or more, and how you will maintain records for 7 years. Once all three parts are drafted, have senior management formally approve the program. Document the approval — date, who approved, and version number.
Source: AML Simple suggested milestones
Weeks 7–5 — People and systems
- 7
Week 7 (12–18 May) — Appoint your compliance officer
Your compliance officer must be at senior management level — typically the principal in a 3-person agency. Document the appointment in writing. This person will implement the program, oversee CDD, ensure reports are filed on time, and be your point of contact with AUSTRAC. They need to understand your obligations — set aside time this week for them to read your completed program.
- 8
Week 6 (19–25 May) — Conduct employee due diligence
Before any staff member performs AML-relevant duties, you must conduct background checks appropriate to their role. For a small agency, this typically means identity verification, reference checks, and a criminal history consideration. Document who you checked, what process you followed, and when. Keep these records for 7 years.
- 9
Week 5 (26 May–1 June) — Deliver initial staff training
Every staff member who has AML-relevant duties must be trained before they perform those duties. Run a structured session covering: your obligations under the Act, your agency's CDD procedures, how to identify red flags, how to escalate concerns to the compliance officer, and the tipping-off offence. Document attendance — name, date, topics covered. Keep training records for 7 years.
Source: AML Simple suggested milestones
Weeks 4–2 — Testing and readiness
- 10
Week 4 (2–8 June) — Set up your CDD workflow
Build the practical process your agents will use from 1 July. This means: a way to collect full legal name, date of birth, and residential address; a method to verify identity (in-person document inspection, video call, or electronic verification via the Document Verification Service); a way to run DFAT Consolidated List and PEP screening; and a record-keeping system to capture the outcome with date and method. Test it end-to-end before obligations go live.
- 11
Week 3 (9–15 June) — Run a dry-run transaction
Walk through your full CDD workflow using a hypothetical client. Can you collect all required information? Can you verify identity using your chosen method? Can you run screening and record the result? Can you assign a risk rating? Identify any gaps and fix them before 1 July. If your workflow breaks on a dry run, it will break on a real client.
- 12
Week 2 (16–22 June) — Check your enrolment and notify AUSTRAC of your compliance officer
Log into AUSTRAC Online and confirm your enrolment is complete and your business details are current. Notify AUSTRAC of your compliance officer — the statutory deadline is 29 July, but doing it now removes one thing from your plate. Check that your compliance officer's details are accurate.
Source: AML Simple suggested milestones
Week 1 — Final checks
- 13
Week 1 (23–30 June) — Final readiness check before go-live
Work through this checklist before 1 July: (1) AUSTRAC enrolment complete ✓ (2) ML/TF/PF risk assessment signed off by senior management ✓ (3) AML/CTF program documented and approved ✓ (4) Compliance officer appointed and notified to AUSTRAC ✓ (5) Employee due diligence completed for all AML-relevant staff ✓ (6) All relevant staff trained before performing AML duties ✓ (7) CDD workflow tested and operational ✓ (8) Screening capability in place (DFAT + PEP) ✓ (9) Record-keeping system ready ✓ If any item is incomplete, this is your last week to fix it.
Source: AML Simple suggested milestones
From 1 July — the 13 ongoing obligations begin
When obligations commence, your preparation phase ends and your ongoing compliance phase begins. From 1 July:
Ongoing obligations from 1 July 2026
Start the countdown today
The agencies that will be compliant by 1 July are the ones that start in April, not June. AML Simple guides you through each preparation step — risk assessment, program generation, CDD setup, and client screening — in a structured workflow built on the AUSTRAC Program Starter Kit.
58 days until obligations commence
1 July 2026
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