AML compliance in franchise networks: what each office is responsible for — AML Simple

Franchise head offices are centralising AML compliance. Each separately-incorporated office is still individually liable.

Two of Australia's largest franchise networks made moves in the last week.

Woodards Group deployed a centralised coordination model across its 23 offices, with head office managing the complex tasks (suspicious matter reporting, audits, monitoring) while individual offices handle initial client verification through a shared digital platform.

Barry Plant appointed Kyrstie Nolan as Head of Operations specifically to lead the network's AML/CTF rollout, paired with the My Databoss platform.

Both networks are treating AML compliance as a serious operational transformation.

What neither arrangement changes is the legal position of each franchise office.

Each office with its own ABN is its own reporting entity

Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, reporting entity status attaches to the legal entity that provides a designated service.

For real estate agencies, the designated service is brokering the purchase, sale, or transfer of property.

If each franchise office operates under its own ABN, each office is its own reporting entity under the Act.

That means each office must independently:

Enrol with AUSTRAC by 29 July 2026
Appoint a compliance officer and notify AUSTRAC by 29 July 2026
Develop and implement an AML/CTF program
Conduct customer due diligence before providing designated services (limited deferrals exist under s 29 of the Act for certain contexts including auction settings, but the conditions are strict and your specific legal structure and circumstances determine whether they apply)
File Suspicious Matter Reports and Threshold Transaction Reports where it is the reporting entity liable for that obligation
Maintain records for at least seven years

Head office cannot enrol on behalf of a separately-incorporated office.

Head office cannot serve as the compliance officer for a separately-incorporated office.

Civil penalties for non-compliance can reach up to A$33,000,000 per contravention for a body corporate, or up to A$6,600,000 per contravention for an individual.

What centralised coordination can help with

A group-level approach can meaningfully reduce the burden on individual offices.

Head office can provide:

A risk assessment template that each office adapts to its specific geography and client mix
A pre-built AML/CTF program structure that offices customise to their circumstances
Staff training content and a delivery mechanism (individual offices must still maintain records showing each staff member completed training before performing AML-relevant duties)
Access to a shared client screening platform for PEP, sanctions, and adverse media checks
An internal reporting framework so network leadership can monitor compliance health across offices

The "Group Reporting Model" referenced in industry coverage of the Woodards approach is an operational term describing how the network organises its internal compliance workflow.

It is not an AUSTRAC designation, and it does not modify each separately-incorporated office's legal obligations.

Five questions to ask your franchisor before 1 July 2026

If you operate a franchise office, do not assume head office has your compliance covered.

Get clear answers before the 1 July 2026 deadline:

Does our franchise agreement say head office will manage our AUSTRAC obligations, or are we responsible for our own enrolment?
Has head office produced an AML/CTF program template we can adopt and customise for our office?
What screening platform does the network use, and is our office already configured on it?
Who is the compliance officer for our specific office, and have they been notified to AUSTRAC?
What training has head office delivered, and do we have records for each staff member who performs AML-relevant duties?

If you can't get clear answers, your office's compliance is likely incomplete regardless of what head office is doing.

Getting your office compliant

AML Simple walks each office through the requirements: building an AML/CTF program, conducting customer due diligence, running PEP and sanctions screening, and maintaining the records AUSTRAC requires.

Full access on paid plans is free until 1 July 2026.

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This post is general information about obligations under the AML/CTF Act 2006. It is not legal or compliance advice. Consult a qualified compliance professional for advice specific to your agency.