Real Estate AML Starter Kit: Step-by-Step Setup For AUSTRAC

If you’re running a real estate agency in Australia, you’re likely aware that anti-money laundering and counter-terrorism financing (AML/CTF) obligations are heading your way. The Australian Transaction Reports and Analysis Centre (AUSTRAC) has made it clear: real estate is a high-risk sector for money laundering, and compliance is no longer optional. The good news? You don’t need to build your program from scratch. AUSTRAC’s real estate AML starter kit gives you the templates, checklists, and guidance to get compliant without hiring a consultant or drowning in paperwork.

This guide walks you through exactly how to use AUSTRAC’s resources to set up a practical compliance program for your agency. We’ll cover the core components, risk assessments, customer due diligence, and reporting obligations, and show you how to customise the templates for your specific operations. Whether you’re a solo agent or managing a small team, you’ll find actionable steps to meet your legal requirements.

At StackGo, we help regulated businesses like real estate agencies verify client identities directly within their existing customer relationship management (CRM). Once your AML program is in place, tools like IdentityCheck can streamline the customer due diligence process we’ll discuss below. But first, let’s get your foundations sorted.

What the AUSTRAC real estate starter kit covers

The real estate AML starter kit provides you with three main resources: a written AML/CTF program template, a customer due diligence checklist, and supporting guidance documents. These aren’t generic compliance materials. AUSTRAC designed them specifically for small real estate agencies handling property sales and management, with practical language that reflects how your business actually operates.

Templates and program documents

You’ll find a customisable AML/CTF program template that covers all mandatory sections required under the Act. This includes your risk assessment framework, governance structure, customer identification procedures, and ongoing monitoring protocols. The template runs approximately 30 pages but uses plain language rather than legal jargon.

AUSTRAC also provides a Part A document that explains your obligations in detail, walking through each section of the program template. You can use this as a reference guide when customising the templates for your specific agency operations.

Customer identification checklists

The starter kit includes step-by-step verification checklists for different customer types: individuals, companies, and trusts. Each checklist specifies exactly what documents you need to collect, how to verify them, and when you can use simplified versus standard procedures. You’ll also find guidance on handling beneficial ownership requirements for corporate entities.

Risk assessment frameworks

AUSTRAC provides a risk matrix template that helps you assess money laundering and terrorism financing risks specific to real estate. The framework considers factors like transaction size, customer profile, property location, and payment methods. You’ll score each risk factor and determine appropriate mitigation controls based on your assessment results.

The kit also includes example risk scenarios common in property transactions, such as cash deposits, offshore buyers, and third-party payments.

Step 1. Confirm you are in scope and enrol

Before you customise the real estate aml starter kit templates, you need to determine whether your agency falls under AUSTRAC’s reporting obligations. Not every property business needs to comply, so your first step involves checking the specific triggers that bring you into scope.

Check if AML/CTF applies to your agency

You’re in scope if your agency acts as a selling or buying agent in the sale, purchase or transfer of real estate, or if you sell property you developed without an independent agent. These are AUSTRAC’s real estate designated services, and there is no dollar threshold for them. The A$10,000 figure in the regime applies only to threshold transaction reports, when your agency itself receives or pays physical cash of A$10,000 or more.

Property management and leases of 30 years or less are out of scope, so an agency that only manages rentals does not need to enrol. Most agencies that sell property will be in scope.

Complete your AUSTRAC enrolment

Once you confirm you’re in scope, you must enrol with AUSTRAC within 28 days of providing your first designated service. You’ll need your Australian Business Number (ABN), business details, and contact information for the compliance officer. The enrolment process takes approximately 15 minutes through AUSTRAC’s online portal.

Step 2. Build your AML and CTF program and controls

Now that you’ve enrolled, you need to adapt the program template from the real estate aml starter kit to match your agency’s operations. This step involves customising the standard document with your specific business details, risk assessment outcomes, and control measures. You’re not writing from scratch, but you do need to make the template reflect your actual procedures.

Customise the program template

Open the Part B template and replace all placeholder text with your agency information. You’ll need to specify your governance structure, including who serves as your compliance officer and what authority they hold. Document your business structure, the types of property transactions you handle, and your geographic service areas.

Add your agency’s specific risk scenarios based on your typical client profile. For example, if you primarily handle residential sales under $2 million, your risk assessment will differ from agencies dealing with commercial properties or international buyers. The template provides example scenarios, but you need to reflect your actual business risks.

Document your risk controls

Create a controls matrix that links each identified risk to specific mitigation measures. Your controls might include transaction monitoring thresholds, enhanced due diligence triggers, or approval requirements for high-risk clients. The starter kit provides a basic framework, but you need to specify exactly what actions your team will take when they encounter each risk type.

Your written program becomes your legal obligation, so ensure every control you document is actually implemented in practice.

Step 3. Set up customer due diligence workflow

The customer due diligence workflow forms the operational heart of your compliance program. You need to establish when verification happens, what documents your team collects, and how they confirm identity before any transaction proceeds. The real estate aml starter kit provides checklists you must integrate into existing procedures.

Create your verification checklist

Build a step-by-step checklist that your team follows for every client. This should specify the exact documents required for individuals (driver’s licence or passport plus secondary document), companies (ASIC extract and director identification), and trusts (trust deed and trustee verification). Your team must physically sight original documents or certified copies, not photocopies.

Document your verification timeline in the checklist. You must complete customer due diligence (CDD) before providing the designated service, which means before accepting any property listing or executing a sale contract.

Your team needs clear instructions on what to do when a client cannot provide standard identification documents.

Two checks on every sale

In a sale, the seller and the buyer are both your customers, so every sale has two checks. Verify your own client before you start acting for them. For the party you do not act for, you may delay the check until 28 days after the exchange of contracts or 3 days before the initially agreed settlement date, whichever is earlier (AML/CTF Rules, section 6-32). The delay applies only where it is essential to avoid interrupting the ordinary course of business and the extra risk is low, and your program must say when you use it. More detail: AML/CTF obligations for real estate agents.

Your client: before you act. The other party: by the earlier of 28 days after exchange or 3 days before the initially agreed settlement date.

Implement verification procedures

Set up a document collection system that maintains verification records for seven years. Each file must contain copies of identification documents, verification dates, and the staff member who completed the check.

Train your team on when to escalate unusual cases to your compliance officer, including clients who cannot provide standard ID or transactions that trigger your risk thresholds.

Step 4. Reporting and record keeping routines

Your compliance obligations extend beyond customer verification. You must establish reporting triggers and maintain detailed records of all transactions and due diligence activities. The real estate aml starter kit includes templates for both routine reporting and record retention systems that meet AUSTRAC’s seven-year requirement.

Set up reporting triggers

You need to file Suspicious Matter Reports (SMRs) within three business days whenever you form a suspicion about money laundering or terrorism financing. Common triggers include clients who avoid identification requirements, use multiple payment sources without explanation, or request unusual transaction structures. Train your team to recognise these red flags and escalate immediately to your compliance officer.

You must also submit Threshold Transaction Reports (TTRs) for cash transactions of $10,000 or more within ten business days. This applies to physical currency only, not bank transfers or cheques.

Your reporting obligation exists even if the transaction doesn’t proceed, as long as you formed a reasonable suspicion.

Maintain compliance records

Keep copies of all identification documents, verification records, and transaction details for seven years after the relationship ends. Your records must include the date verification occurred, who completed it, and what documents you sighted. Store these records securely with access limited to authorised staff only.

Create a retention schedule that specifies when you can destroy old records, ensuring you never delete anything before the seven-year period expires.