The Australian Competition and Consumer Commission (ACCC) has observed that organisations that effectively establish a culture of compliance typically travel through three phases. While the observations were made in relation to the Trade Practices Act 1974, they are equally applicable to reporting entities seeking to achieve compliance with their obligations under the AML/CTF Act. The three phases are:

1. Commitment to comply. Management develops a willingness or commitment to address compliance issues and allocate the resources to achieve it.
2. Compliance know-how. Specialist personnel are appointed and made accountable for compliance program development and internal and external expertise is sought and assimilated. Corporate strategy takes account of compliance. Policies and procedures are developed to address compliance issues.
3. Compliance as business practice. Compliance becomes the way business is done and is no longer external to it. Compliance policies are considered integral to business objectives. Operational procedures take account of compliance; the performance of work duties in compliance with the law is the business norm.