The done-for-you AML/CTF program for real estate agencies, sales agents and buyer's agents — 25 editable documents, forms & registers plus the offline AML Compliance Cockpit — built for independent agencies and ready before the 29 July 2026 deadline.
If your agency does any of the following, you provide a "designated service" under the reformed AML/CTF Act — and the full set of obligations applies. It does not matter whether you are a franchise office, an independent agency or a solo buyer's agent: the obligations attach to the service, not the brand on the door.
Listing and selling a property for a vendor, or representing a purchaser in acquiring real estate — the core activity of a sales agency. When you broker the deal, you provide a designated service.
Searching for, negotiating, and acquiring property on behalf of a buyer client — whether residential or commercial — is captured the same way a selling agency's service is.
Acting as the intermediary that introduces parties and facilitates the transfer of a property or an interest in real estate, including off-the-plan and house-and-land arrangements.
Handling deposit monies, holding funds in your trust account, or disbursing settlement funds in connection with a real estate transaction you are acting on.
Conducting price and contract negotiations on behalf of a vendor or purchaser as part of brokering the sale, purchase or transfer of the property.
Pure property management — collecting rent and managing tenancies — with no involvement in the sale, purchase or transfer of the property is generally not a designated service on its own. Always verify against your specific facts.
Enrolment opened 31 March 2026. New entities providing designated services from 1 July must enrol in AUSTRAC Online and notify their compliance officer by 29 July 2026.
Identify and document the money laundering, terrorism financing and proliferation financing risks specific to your agency, your buyer and vendor profiles, and the transactions you handle.
Develop and maintain written policies, procedures, systems and controls that manage and mitigate the risks you have identified across your transactions.
Designate a compliance officer and notify AUSTRAC of the appointment by 29 July 2026. For most agencies this is the principal or licensee-in-charge.
Identify and verify your vendors and buyers (name, address, DOB for individuals) and identify beneficial owners who own or control 25% or more of a corporate or trust buyer — including through nominee and layered structures.
Lodge suspicious matter reports (24 hours for terrorism financing; 3 business days for other suspicions). Lodge threshold transaction reports for physical cash of $10,000 or more within 10 business days.
Retain CDD records, transaction records and AML/CTF program documents for the required periods — critical if AUSTRAC ever requests them.
Arrange an independent evaluation of your whole AML/CTF program — not just the policies, but the entire program — at the intervals required under the reformed regime.
A bespoke AML/CTF program from a specialist consultant typically starts at $10,000 for a small agency and can reach $30,000 or more — before annual maintenance fees. That is a significant bill for an independent agency, for documents you then still have to read, customise and implement yourself.
This Kit gives you the same starting documents — written specifically for real estate agencies, mapped to the reformed obligations — for a fraction of that cost.
Look inside — see real sample pages →
The 13 core policies and procedures below, plus a full operational layer (fillable KYC forms for vendors and buyers, beneficial-ownership & source-of-funds forms, PEP/sanctions screening, deposit & settlement monitoring, SMR/TTR & training registers, compliance calendar and more), and the interactive Cockpit. Every document is editable Microsoft Word with [Agency Name], [Date] and [Compliance Officer] merge fields you fill in with your own details.
Step-by-step AUSTRAC Online enrolment walkthrough, key dates, and a pre-launch checklist for the 29 July 2026 deadline.
A working risk assessment covering money laundering, terrorism financing and proliferation financing — with real-estate-specific risk factors: offshore and nominee buyers, large or structured cash deposits, third-party payers, undervalue transfers and rapid resale.
Your core policies, procedures, systems and controls mapped to the reformed obligations. The heart of a compliant AML/CTF program.
Initial CDD for individual vendors and buyers (name, address, DOB) and corporate/trust buyers, plus beneficial ownership verification to the 25% control threshold through complex structures.
Additional steps for higher-risk parties: PEPs, offshore buyers and foreign-sourced funds, opaque ownership structures, nominee arrangements and clients from higher-risk jurisdictions.
Appointment letter and role description to formally designate your AML/CTF compliance officer — required by the 29 July 2026 deadline.
Suspicious matter reporting workflow for real estate context (e.g. unexplained source of deposit funds, structured cash, last-minute buyer substitution), escalation procedure, and a ready-to-complete SMR template. 24-hour TF / 3 business day standard SMR timeframes included.
Threshold transaction reporting for physical cash of $10,000 or more (lodge within 10 business days), with a lodgement template and guidance on detecting structured deposits.
An AML/CTF training framework for your sales team and property staff, and an employee due-diligence process appropriate for an agency environment.
What records to keep, for how long, and how — mapped to AML/CTF record-keeping requirements. Integrates with existing sales and trust-account file management.
Scope brief and structured checklist to commission the independent evaluation of your whole AML/CTF program, required periodically under the reformed regime.
Accountability structure, principal/director reporting lines and an oversight register so the agency principal can demonstrate governance oversight of the AML/CTF program.
How to use the included interactive risk-rating tool on a vendor or buyer and keep its output on the client's CDD file.
Most kits stop at policies. These are the practical, fillable tools your team uses on every deal — so you can run the program, not just file it.
The front sheet that ties every policy, procedure, form and register together with owners, approval dates and the review cycle.
Document why each of your services is — or isn't — a designated service, with a geographic-link check and sign-off. Your "am I a reporting entity?" evidence.
Four ready-to-use forms — individual/sole trader, company, trust, and partnership — each with the identity fields, verification-evidence table and risk rating for vendors and buyers.
Capture every individual who owns or controls 25% or more of a corporate or trust buyer — including through nominees and layered structures — with verification and sign-off.
A structured questionnaire and evidence checklist for higher-risk buyers, offshore funds, third-party payers and unexplained deposit sources.
When and how to screen buyers and vendors against the DFAT Consolidated List and PEP indicators, how to handle a hit, plus the screening register to log it.
Review cadence, trigger events and the unusual-activity signals to watch for across a transaction, with a monitoring log to evidence it.
A practical, real-estate-specific one-pager so every agent knows the warning signs — offshore buyers, structured cash, undervalue transfers, last-minute substitution — and exactly what to do (without tipping off).
Ready registers to record every suspicious-matter and threshold-transaction report considered and lodged, with AUSTRAC references and retention.
Track who was trained, on what and when — plus an attestation each staff member signs acknowledging their obligations.
A pre-populated calendar of recurring obligations — reviews, training, screening, record checks, independent evaluation — so nothing slips.
The structure your independent reviewer completes — findings, ratings, recommendations and a management response with due dates.
An offline, browser-based command centre tailored for real estate agencies, included with every licence. Seven tools in one private workspace: an "Am I caught?" scope check, a client ML/TF risk-rating engine for vendors and buyers, a CDD checklist generator, automatic SMR and TTR draft builders, a deadline & obligations tracker, and a records register. Everything runs in your browser — no data leaves your computer, nothing is uploaded. It turns a folder of documents into a working compliance system.
The complete 25-piece kit (documents, forms & registers) and the AML Compliance Cockpit, licensed for your agency — no tiers, no upsells, no subscription.
For your agency — sales agency or buyer's agency. The principal or licensee-in-charge is the AML/CTF compliance officer. Built for independent offices and small-to-mid agencies.
| Feature | This Kit — $1,470 | Specialist consultant | Generic online template |
|---|---|---|---|
| Upfront cost | $1,470 one-off | $10,000–$30,000+ | Varies |
| Time to get documents | Instant download | Weeks of scoping & drafting | Instant |
| Written for real estate agencies | Yes — fully adapted | Depends on consultant | Usually financial-services generic |
| Covers reformed program structure (no Part A/B) | Yes | Depends on consultant | Often out of date |
| Offshore / nominee buyer & cash-deposit risk factors | Yes | Depends on scope | Rarely |
| Beneficial ownership — 25% threshold | Yes | Depends on scope | Sometimes |
| Editable Word documents | Yes | Often locked PDFs | Sometimes |
| Interactive client risk-rating tool | Yes | Not standard | No |
| AML Compliance Cockpit (offline) | Included | No | No |
| 12-month update guarantee | Yes | Re-quoted on updates | No |
Check out in a couple of minutes. Secure payment, instant access — no subscription, no renewal.
Get all 25 editable documents, forms & registers and the offline AML Compliance Cockpit the moment you pay.
Drop in your agency name, compliance officer's name and your details — the structure and substance are already done.
Adopt your program, brief your sales team, run the risk-rating tool on your deals and enrol with AUSTRAC by 29 July 2026.
Our franchise network will sort this out for us."
Some franchise groups are publishing guidance for their offices — and that guidance points you back to your own obligations. The enrolment, the program, the customer due diligence and the reporting obligations attach to the reporting entity that provides the designated service. If your office brokers sales, those obligations are yours. Confirm exactly what your network covers; independents and many franchise offices have to build their own program.
We mostly do property management — this doesn't apply to us."
Pure property management — collecting rent and managing tenancies — with no involvement in the sale, purchase or transfer of the property is generally not a designated service on its own. But the moment your office acts for a vendor or buyer, brokers a transfer, or handles deposit or settlement funds, the obligations apply. Most agencies that "mostly" do property management still list and sell from time to time.
I'll wait and see what AUSTRAC says before spending money."
Obligations start 1 July 2026. Enrolment closes 29 July 2026. Waiting costs you the window that already exists. AUSTRAC has published its guidance; the regime is not going to be paused. Getting the documents now gives you weeks to actually implement them — which is the part that takes time.
I'll just hire a consultant when the time comes."
A good AML/CTF consultant for a small agency typically charges $10,000–$30,000 and takes several weeks to deliver — and that bespoke build, not this kit, is what reaches into five figures. The deadline is weeks away. This Kit does not replace a specialist if your risk profile is complex — but for the large majority of independent and small-to-mid agencies providing standard designated services, it gives you what you need to start from a structured, accurate base.
Isn't there a free AUSTRAC starter kit?"
Yes — and we'll point you to it. AUSTRAC publishes free sector program starter kits aimed at small, low-complexity businesses (broadly, up to 15 staff). If you run a small agency doing straightforward local sales, start there — it may be enough. This edition is for agencies that want the program finished: every policy, register and form fully written and real-estate-tailored, plus the operational layer and offline Cockpit the free framework leaves blank — so you can adopt an audit-ready program this week instead of building it from a blank template. It earns its price most clearly when you handle higher-value or cross-border buyers, corporate or trust purchasers, or sit above the small-business line. We're the finished build — not ongoing screening software, consultant sign-off, or the independent evaluation AUSTRAC requires at least every three years.
How is this different from generic AML templates online?"
Most generic templates were written for financial services firms under the old Part A / Part B program structure — which the 2024 reforms have replaced. This kit is built on the reformed structure (ML/TF risk assessment + AML/CTF policies + independent evaluation of the whole program) and every risk factor, designated service description and CDD procedure is specific to real estate: offshore and nominee buyers, structured cash deposits, beneficial ownership through corporate and trust buyers, deposit and settlement funds.
What if the regulations change after I buy?"
You receive 12 months of free updates. If AUSTRAC updates its Tranche 2 guidance for the real estate sector within 12 months of your purchase, you get the revised documents at no extra cost. Beyond 12 months you keep everything you downloaded; the core obligations from the 2024 amendments are unlikely to change substantially in that window.
If AUSTRAC updates its Tranche 2 guidance for real estate agencies within 12 months of your purchase, you receive the updated documents free of charge. Buy once, stay current through the rollout year.
This Kit provides done-for-you documents that you implement. We do not promise any particular regulatory outcome, that you will avoid penalties, or that AUSTRAC will be satisfied with your program — compliance depends entirely on your own implementation, training and ongoing oversight. This Kit is general compliance support material, not legal advice, and does not create a professional relationship. It is not affiliated with or endorsed by AUSTRAC, the Attorney-General's Department, or any government or industry body.
We sell to risk-averse professionals, so we're upfront about what this is, how it's built, and where its limits are.
Published by Axior Labs (ABN 91 949 773 596), Bendigo, Victoria.
Yes. Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) as amended by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth), real estate businesses that provide specified "designated services" become reporting entities from 1 July 2026. The designated services include acting for a seller or buyer in the sale, purchase or transfer of real estate, buyer's agency, brokering or facilitating transfers, and handling deposit or settlement funds — the core activity of most sales agencies. You can verify your status using AUSTRAC's "Check if you may be regulated" tool at austrac.gov.au.
Pure property management — collecting rent and managing tenancies, with no involvement in the sale, purchase or transfer of the property — is generally understood not to be a designated service on its own. However, the moment your office acts for a vendor or buyer, brokers a transfer, or receives, holds or disburses deposit or settlement funds in connection with a transaction, those specific services trigger the obligations. Many agencies that primarily manage rentals still list and sell occasionally. Use AUSTRAC's self-assessment tool or consult a lawyer to confirm your specific position.
The old Part A / Part B program structure has been replaced by the 2024 reforms. Tranche 2 entities — including real estate agencies — must produce three things under the new structure: (1) an ML/TF and proliferation financing risk assessment, (2) AML/CTF policies, procedures, systems and controls, and (3) arrange a periodic independent evaluation of the entire AML/CTF program. This Kit is built on the reformed structure — not the old Part A / Part B model. Any template that still refers to "Part A" and "Part B" is out of date.
For individual clients, initial customer due diligence requires collecting at minimum: full name and either residential address or date of birth (risk-based). The full standard set is full name + residential address + date of birth. For corporate and trust buyers, you must also identify beneficial owners — individuals who own or control 25% or more — following the chain of ownership through companies, trusts and nominee arrangements to the natural person. Source: austrac.gov.au AML/CTF reform guidance on initial CDD.
SMR (suspicious matter report): must be lodged within 24 hours of forming a suspicion that a matter is related to terrorism financing, or within 3 business days for any other suspicion. Do not tell the client you have lodged an SMR — tipping-off provisions apply to SMR-related information. TTR (threshold transaction report): physical currency of $10,000 or more (or foreign equivalent) must be reported to AUSTRAC within 10 business days of the transaction. Source: austrac.gov.au reporting guidance.
No. AMLCompliant is an independent product. We are not affiliated with, endorsed by, or acting on behalf of AUSTRAC, the Attorney-General's Department, or any government agency or real estate industry body. We reference AUSTRAC's published guidance to ensure the documents map to actual obligations, but the Kit is our own work and does not represent official guidance from any of those bodies.
No. The Kit is general compliance support material — editable templates and guidance you adapt to your own agency circumstances. It is not legal advice and does not create a professional relationship. If you need advice about your specific obligations, engage a qualified Australian lawyer with AML/CTF expertise. Your state real estate institute may also publish sector-specific guidance — check their website for current member resources.
All 25 documents, forms and registers are editable Microsoft Word files (.docx) with clearly marked merge fields — [Agency Name], [Date], [Compliance Officer Full Name] and similar — for you to fill in with your own agency details. The AML Compliance Cockpit is a single self-contained HTML file that runs offline in any browser (Chrome, Firefox, Edge, Safari) — it checks if you're caught, risk-rates vendors and buyers, and drafts your SMR/TTR. No internet connection required, no data leaves your computer. You download everything immediately after purchase.
No — and we will not pretend otherwise. The Kit gives you the starting documents for an AML/CTF program. Compliance comes from actually implementing them: adopting the policies, training your staff on AML/CTF obligations, enrolling with AUSTRAC, doing customer due diligence on your vendors and buyers, keeping records and lodging reports when required. We provide accurate, real-estate-specific starting documents; you provide the implementation and ongoing oversight. AUSTRAC assesses what you do in practice, not what documents you own.
25 editable documents, forms and registers and the AML Compliance Cockpit — written for real estate agencies, sales agents and buyer's agents, mapped to the reformed obligations, delivered the moment you pay.
Get the Kit — $1,470