AUSTRAC Compliance Checklist for Real Estate Agents (Effective 1 July 2026)

Below is a compliance checklist tailored for real estate agents in Australia, aligning with AUSTRAC’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations effective from 1 July 2026.

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AUSTRAC Compliance Checklist

1. Determine Regulatory Status

• Confirm if your business is a ‘tranche 2’ entity under the expanded AML/CTF regime.
• Utilize AUSTRAC’s ‘Check if you’ll be regulated’ tool to assess your obligations.

2. Enrolment with AUSTRAC

• Enrol with AUSTRAC between 31 March and 30 June 2026.
• Ensure accurate enrolment details, including business structure, services provided, and geographical links to Australia.

3. Develop and Implement AML/CTF Program

• Conduct a Money Laundering/Terrorism Financing (ML/TF) risk assessment to identify and assess risks associated with your business activities.
• Establish an AML/CTF program that includes:
  • Policies and procedures to manage identified risks.
  • Appointment of a compliance officer.
  • Staff training and awareness programs.
  • Ongoing monitoring and review mechanisms.

4. Customer Due Diligence (CDD)

• Implement procedures for customer identification and verification in accordance with AUSTRAC guidelines.
• Conduct ongoing monitoring of customer transactions to detect suspicious activities.
• Maintain records of CDD processes and outcomes.

5. Reporting Obligations

• Submit Suspicious Matter Reports (SMRs) within the required timeframes:
  • Within 24 hours for terrorism financing.
  • Within three business days for other suspicious matters.
• File Threshold Transaction Reports (TTRs) for cash transactions of A$10,000 or more.
• Report cross-border movements of physical currency of A$10,000 or more.

6. Record-Keeping

• Maintain comprehensive records of:
  • Customer identification and verification documents.
  • Transaction details and reports.
  • AML/CTF program and compliance activities.
• Ensure records are stored securely and retained for the mandated period.

7. Compliance Reporting

• Submit an annual compliance report to AUSTRAC between 1 January and 31 March each year, detailing:
  • Implementation and effectiveness of AML/CTF program.
  • Staff training and awareness initiatives.
  • Compliance with reporting and record-keeping obligations.

8. Governance and Oversight

• Ensure senior management oversight of AML/CTF compliance activities.
• Establish a governance framework that supports the effective implementation of AML/CTF obligations.

9. Training and Awareness

• Provide regular training to staff on AML/CTF obligations and procedures.
• Ensure training programs are updated to reflect changes in legislation and emerging risks.

10. Ongoing Monitoring and Review

• Conduct regular reviews of AML/CTF policies and procedures to ensure their effectiveness.
• Implement corrective actions where deficiencies are identified.

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For detailed guidance and resources, visit AUSTRAC’s Financial Service Providers page and the AML/CTF Reform page.

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