AML/CTF: Compliance without the complexity

New AML/CTF compliance requirements for designated service providers

The Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Amendment Act 2024 became law on 10 December 2024 and significantly impacts the real estate industry, legal industry and individuals buying and selling property. The reforms aim to close regulatory gaps by extending AML/CTF obligations to previously unregulated sectors, including real estate.

If your business is now required to comply with AML/CTF regulations, it’s essential to understand your obligations and begin preparations as soon as possible. While the new requirements don’t take effect until 1 July 2026, the short compliance timeline and the limited availability of AML/CTF specialists in Australia mean demand for expertise will rise as the deadline approaches.

Under this new regime, real estate agents are classified as a PSP, meaning you must adhere to AML/CTF regulations, and the services you provide are recognised as ‘Designated Services’.

This means your agency is subject to AML/CTF compliance measures, broadly covering:

Conducting employment due diligence (EDD) obligations
Conducting customer due diligence (CDD) including verifying clients' identities
Reporting suspicious transactions to AUSTRAC
Keeping records of transactions and client interactions, and
Implementing a risk-based AML/CTF compliance program.

Get ready for Tranche 2: Essential AML/CTF training for real estate agents

Supporting your agency through Tranche 2

As this law is fast approaching a compliance deadline, your agency should now be in the planning phase and well on your way to developing an internal compliance program.  

As your leading proptech provider, we are working on readying Securexchange to be compliance ready for any additional employee checks and client onboarding checks you will need to conduct. Not every agency is the same, and so our Business Development Managers are ready to talk with you about your specific processes.  

We are committed to your agency’s ongoing education and training in relation to the regime and we will be releasing training for your agency in the coming months.  

We are also thrilled to announce that we are working in partnership with Grant Thornton to provide you with services to support the development and implementation of your agency’s internal AML/CTF compliance framework.

Learn more about Securexchange's AML/CTF solutions

Finally, Securexchange is committed to continuing to provide input and guidance into the AUSTRAC consultation phase of the regime and will advocate for property technology that serves your agency’s best interests.

Checklist: Your agency’s journey to compliance

AML/CTF Compliance Program

Agencies will need to develop or choose a service provider to implement an AML/CTF Compliance Program

AML/CTF project lead appointed
Internal risk assessments to identify vulnerabilities
Staff training on AML/CTF obligations
Policies and procedures for CDD, reporting, and record-keeping
Regular audits and updates to reflect new risks

Customer Due Diligence (CDD) & Know Your Client (KYC)

Real estate agents will need to verify their clients’ identities before providing a Designated Service. This includes:

Identifying and verifying clients using reliable, independent documents (e.g., passports, driver's licenses).
Identifying beneficial owners (e.g., trusts, companies) to prevent the use of real estate services for money laundering.
Assessing risk : Firms must classify clients based on risk levels (e.g., high-risk clients may require enhanced due diligence).
Ongoing monitoring: Regularly review client activities to detect suspicious transactions.

Suspicious Matter Reporting (SMR)

If a transaction or activity appears suspicious—such as unusual payments, complex property transfers, or clients avoiding verification—agencies must report it to AUSTRAC.

Record-Keeping Requirements

Real estate agents must maintain detailed records for at least seven years