What a completed AML/CTF program looks like for a real estate agency

AUSTRAC's Program Starter Kit is three Word documents. Nobody shows you what they look like when they're done.

AUSTRAC enrolment opened on 31 March 2026. Agencies that have downloaded the Starter Kit have the template. What most don't have is a sense of what the completed version looks like for a small residential agency.

This post walks through each component using a hypothetical five-person agency as the example.

The example is illustrative. Your program must reflect your actual business: your customers, your services, your geography, and your risk profile. Use this as a reference point to understand the scope, not as a document to copy.

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What the AUSTRAC Program Starter Kit contains

AUSTRAC published the Program Starter Kit specifically for agencies with 15 or fewer personnel providing one designated service — brokering the purchase, sale, or transfer of real estate.

It contains three documents:

• A guide explaining what to include and what choices to make
• A risk assessment document, pre-populated with real estate risk categories for you to complete and sign off
• A process document covering the policies and procedures for how your agency operates

Together, these three documents become your AML/CTF program once they're customised and signed off by senior management.

You can download the Starter Kit from AUSTRAC's real estate guidance page.

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Worked example: Sunrise Property Group, a five-person agency

Sunrise Property Group is a fictional agency in Western Sydney. Five staff, including the principal. They sell residential property, deal with buyers in person, and their client base is mostly local owner-occupiers and residential investors. No offshore buyers, no cash transactions, no complex ownership structures.

This is about as low-risk a real estate operation as you will find. Their program reflects that.

The risk assessment

The risk assessment covers four mandatory categories: customers, services, delivery channels, and geographic locations.

Customers. Sunrise serves local owner-occupiers and residential investors. No politically exposed persons, no non-residents, no companies or trusts with unclear beneficial ownership. Customer risk: lower.

Services. One designated service: brokering the sale of residential property. All transactions are financed in the normal way. No cash purchases. Service risk: lower.

Delivery channels. All clients are met in person. No remote-only buyers, no online-only interactions. Channel risk: lower.

Geographic locations. All transactions are in Western Sydney. Clients and their funds originate locally. No connections to high-risk jurisdictions or FATF grey-listed countries. Geographic risk: lower.

Overall residual risk for Sunrise: lower.

That risk level matters. A lower residual risk means standard CDD procedures are sufficient. It means enhanced due diligence is only triggered by specific red flags, not applied routinely.

The risk assessment document must be dated, version-numbered, and signed off by senior management. It must also include a review schedule — at minimum, a note of what would trigger an update (new services, new markets, regulatory changes).

The program document

The program document contains policies and procedures for every required component. For Sunrise Property Group, each section looks like this.

Compliance officer appointment. The principal, James Nguyen, is appointed as AML/CTF compliance officer at senior management level. The program records his name, role, and the date of appointment. AUSTRAC will be notified of his details by 29 July 2026.

Customer due diligence procedure. Before every transaction, agents collect the buyer's and seller's full legal name, date of birth, and residential address. Agents also confirm whether each client is acting on behalf of another party. If so, that other party is identified and subject to the same CDD process. Identity is verified using a current Australian driver's licence or passport. If a client cannot provide photographic ID, agents follow a two-document alternative: a primary non-photographic document (birth certificate, citizenship certificate) plus a secondary document (utility bill less than three months old, or an ATO notice less than 12 months old). All details are recorded in the agency's CDD log with the document type, number, issuer, expiry date, and the name of the agent who verified it.

Beneficial ownership. For company or trust buyers, agents identify any individual with 25% or more ownership or effective control. That person is subject to the same CDD process as an individual buyer.

Staff training. All four sales agents complete a one-hour AML/CTF induction before their first client interaction. A 30-minute annual refresher is scheduled each July. James keeps dated attendance records in the program file.

Record keeping. All CDD records, training records, and transaction documents are stored for a minimum of seven years, either in the agency's file management system or in physical folders held at the office.

Suspicious matter reports. If any agent suspects money laundering or terrorism financing, they escalate to James immediately. James assesses the situation and files a Suspicious Matter Report (SMR) via AUSTRAC Online if needed: within 24 hours for terrorism financing concerns, within three business days for other suspicious matters. Staff are trained that telling a client an SMR has been or will be filed is a criminal offence under the tipping-off provisions of the Act.

Governance. James reviews the CDD log monthly and reports quarterly to the principal on compliance activity, staff training currency, and any incidents or red flags.

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What you need to customise

If your agency profile is close to Sunrise Property Group, the Starter Kit maps well to your situation.

If you regularly deal with interstate or overseas buyers, work with investors who use complex ownership structures, or conduct transactions without ever meeting clients in person, your risk assessment will look different. Higher inherent risk requires more specific controls, more detail in your CDD procedures, and potentially enhanced due diligence requirements for certain customers.

The Starter Kit's guide walks you through what to change and why. The key principle: every procedure in your program should reflect how your agency actually operates.

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What the Starter Kit does not cover

The Starter Kit is designed for agencies with 15 or fewer personnel and one designated service.

Larger agencies, agencies with multiple designated services (sales and buyer's agent work, for example), or agencies with more complex governance structures will need a more comprehensive program beyond the Starter Kit scope. AUSTRAC's real estate guidance section at austrac.gov.au provides additional direction for those situations.

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91 days until 1 July 2026 (as of 1 April 2026)

Enrolment is now open. The program needs to be operational by 1 July 2026 — not submitted anywhere, but implemented and ready to use.

For a simple agency like Sunrise Property Group, building the program from the Starter Kit takes a few focused hours. The risk assessment is the most analytical part. The procedures section is largely documentation of what your CDD process will be.

Getting started this week means you have time to train staff and bed down the process before obligations commence.

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