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