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.

AUSTRAC: consequences of not complying

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.

If your agency provides a designated service, you must apply to enrol with AUSTRAC within 28 days after you start providing it. If you were required to apply and that deadline has passed, you are in breach of the enrolment obligation and should apply now. That is not the same as an agency that applied on time and is waiting for AUSTRAC to process the application, and it does not apply to businesses that do not provide designated services or whose obligations commence later.

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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Know what applies. Then make it workable.