AML Compliance Checklist
for Real Estate Agencies

Check whether your agency brokers the sale, purchase, or transfer of real estate on behalf of a buyer, seller, transferee, or transferor. If yes, you are in scope and must comply.

Enrolment for Tranche 2 entities opened 31 March 2026. Newly regulated agencies must enrol by 29 July 2026. Do this early and do not wait until July.

Typically your licensee in charge. They must be appointed within 28 days of commencing designated services, and AUSTRAC notified within 14 days of appointment.

Identify and document the money laundering and terrorism financing risks your business faces. Consider your client types, transaction types, geographic areas, and service delivery methods.

Use the AUSTRAC Real Estate Program Starter Kit as your base. Tailor it to your agency's size, services, customer profile, and risk exposure. It must be customised to your business and not used as-is.

Your AML/CTF program must be documented and formally approved by a senior manager before you start providing any designated service from 1 July 2026.

Establish a consistent process for verifying client identity before transacting. Include screening against sanctions lists and identifying Politically Exposed Persons and high-risk clients.

Ensure all team members understand AML/CTF obligations, how to spot red flags, and what to do if suspicious activity is identified. Document that training has been completed.

Keep documentation that demonstrates compliance including CDD records, transaction monitoring, and any suspicious matter reports submitted to AUSTRAC. Records must be retained for the required period.

Your AML/CTF program must be independently evaluated at least every three years. Newly enrolled agencies may wish to conduct their first evaluation earlier. Diarise this now.