AML/CTF for Australian real estate
AML compliance built for real estate operations
Not enrolled? Act now. Enrolment is only the first step.
If you are required to enrol and have missed your deadline to apply, you are already in breach of your enrolment obligation.
This does not apply to businesses that do not provide designated services, to businesses whose obligations commence later, or to businesses that applied on time and are awaiting processing. AUSTRAC enrolment guidance
An enrolment number does not make your agency compliant. You need an operating AML/CTF program, customer checks, risk controls and records that show what your team actually does. Gaps can expose your agency to financial penalties and criminal exploitation.
A practical, Australian-built compliance platform designed around how real estate businesses actually operate.
Enrolled already? You still need to manage the risk.
Enrolment records your business with AUSTRAC. It does not replace your risk assessment, customer due diligence, staff training, reporting or record keeping. A policy sitting in a folder is not enough: your team needs to use it.
Address overdue enrolment
Confirm which services bring your business into scope and address any overdue application promptly.
Put AML controls into daily work
Apply customer checks, train your team and manage the risks your business faces.
Keep evidence of compliance
Record your decisions, assign responsibility and track the gaps you address.
Non-compliance can carry financial penalties.
Failing to enrol or meet AML/CTF obligations can lead to enforcement action. AUSTRAC can issue infringement notices for relevant enrolment, program and customer-check failures, and seek court-imposed civil penalties. The outcome depends on the breach and circumstances.
Enrolment was the first step. What happens inside the agency now?
Enrolling with AUSTRAC registers the business; meeting AUSTRAC real estate requirements day to day depends on workable processes inside the agency.
Identifying when a designated service is being provided
Knowing which instructions trigger AML/CTF obligations under the Act.
Customer identification and verification
Collecting and verifying identity evidence before work starts.
Customer and matter risk assessment
Rating each client and matter so checks match the actual risk.
Enhanced due diligence and escalation
Stepping up scrutiny for higher-risk clients and situations.
Ongoing monitoring
Keeping customer and matter information current over time.
Suspicious-matter decision-making and records
Documenting how concerns are assessed and reported.
Staff responsibilities
Making clear who does what at each stage of a matter.
Compliance oversight
Someone accountable for reviewing that the process is being followed.
Producing organised evidence when questions are asked
Having records ready if AUSTRAC or an auditor asks.
Real estate agencies
Sales and property management, multiple offices and many agents, trust-related processes, and customer-facing workflows that need to be consistent office to office. AML compliance for real estate agents works best when the workflow matches the way the agency already handles a matter.
Buyers' agencies
Buyer-specific relationships and authority to act, transaction stages from engagement to settlement, customer onboarding and risk-based checks proportionate to the matter. Buyers' agent AML obligations sit alongside the broader agency framework and need to be reflected in the same audit trail.
Already have an AML provider?
Use the free scope check as an independent sense-check of whether your current arrangements cover the services you provide and where an operational workflow may still be needed.
Compliance that fits the work
AML software for real estate agencies should fit the way an agency runs. True Comply is configured around the agency, not the other way round.
Guided real-estate workflows
Step-by-step prompts that match a sales or property-management matter.
Customer and matter risk assessment
Risk-rate the client and the transaction, not just a form field.
CDD and enhanced due-diligence records
Identity, verification and EDD evidence in one place.
Escalation and case management
Flag, assign and track higher-risk matters to resolution.
Role-based tasks and accountability
Agents, admins and compliance managers each see what they need to do.
Evidence and audit trail
Every decision is timestamped and linked to the underlying records.
Reporting and oversight
See progress, gaps and exceptions without exporting spreadsheets.
Configurable workflows for different agency models
Sales-only, property management, buyers' agency or combined.
True Comply can be configured around an agency's existing processes and technology environment.
Real compliance experience. Real estate technology experience.
Daniel Baulch brings senior investigations, integrity and regulatory-enforcement experience. Paul is True Comply's technology lead and originally built the core platform around real-estate operations, including the role of the buyer's agent. Together they can demonstrate how the system can be configured around the way an agency actually works.
Real estate AML questions, answered.
Primary sources: AUSTRAC enrolment overview and AUSTRAC: consequences of not complying. General information only, not legal advice — obligations depend on the designated services your business provides.
Start with the two-minute scope check.
Answer a short set of questions about your services and receive an initial indication of where your business may sit under the Tranche 2 reforms. The Tranche 2 scope check is a practical starting point, not legal advice.
Nothing you enter is stored — the scope check runs entirely in your browser.
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Start the conversation
Tell us where your agency is at.
A short note is enough — we'll come back to you with practical next steps. No jargon, no obligation.