AML/CTF staff training requirements for real estate agencies — AML Simple

If a staff member of your agency takes on a new buyer client, asks for their ID, and runs a sanctions screen — they just performed an AML-relevant duty. Under AUSTRAC Tranche 2 rules, they must have received AML/CTF training before doing that. Not after. Not "eventually." Before.

This is one of the requirements that catches agencies off-guard. It is not enough to train staff on CDD after 1 July 2026. You need staff trained and ready before obligations commence.

The fast path: complete training in the platform

AML Simple includes in-platform staff training. Staff members log in to their account (or complete training as part of the onboarding workflow), work through the training module at their own pace, and their completion is recorded automatically.

Training records — who completed training, when, and what was covered — are stored in your account for 7 years automatically.

Three steps to get started:

Sign up to AML Simple — around 2 minutes
Set up your agency profile — your team members can then be invited to complete training
Assign training — staff work through the AML/CTF risk awareness module

Their completion is logged. You have a training record ready for AUSTRAC.

Want the full picture of what training must cover? Here it is.

The legal basis

The training obligation comes from the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, s 26F(4)(e), as inserted by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024. It requires your AML/CTF program to include training for staff who perform — or will perform — AML-relevant functions.

AUSTRAC's Program Starter Kit provides further guidance on training content and frequency.

The key points:

Training is mandatory for staff performing AML-relevant duties
Training must happen before those duties are performed
Ongoing training is required — at minimum annually
Training records must be retained for 7 years

Source: AML/CTF Act 2006, s 26F(4)(e); AUSTRAC Program Starter Kit training guidance

Who needs to be trained?

Any staff member who performs, or will perform, an AML-relevant function needs to be trained. In a real estate agency, that includes:

All agency staff involved in property transactions:

Property agents (sales and buyer's agents) who take on clients and collect identification
Administrative staff who process identity documents or enter client information into systems
Office managers who oversee the CDD process or coordinate compliance activities
The Compliance Officer (who should also have a deeper understanding of the obligations, not just risk awareness)

What does "AML-relevant function" include?

Collecting client identification information
Running sanctions and PEP screens
Assessing client risk ratings
Identifying and escalating suspicious activity
Maintaining AML/CTF records
Any function described in your AML/CTF program as an AML-relevant role

If someone's job description could ever involve any of the above, they need training.

What must training cover?

AUSTRAC's guidance requires training to cover eight content areas:

1. AML/CTF Act obligations What the law requires of the agency and of individual staff. This does not need to be a legislative deep-dive — staff need to understand what they are required to do and why.

2. How to identify suspicious activity Specific, practical examples of suspicious behaviour in real estate transactions. Generic descriptions are not enough — staff need to recognise patterns like cash structuring, reluctance to provide ID, above-market-price purchases, and complex structures with no apparent legitimate purpose.

3. How to escalate concerns internally Who is the Compliance Officer? What is the escalation process? What should a staff member do when they notice something concerning? This needs to be clear and practical.

4. SMR and TTR procedures What a Suspicious Matter Report is, when it must be filed, and the tipping-off rule (that it is a criminal offence to tell the client). Staff do not file SMRs directly in most agencies — but they need to understand what triggers escalation to the Compliance Officer.

5. CDD procedures What information to collect from clients, how to verify it, and what to do when a client cannot provide standard documentation. Staff should know your agency's specific CDD process, not just the general requirement.

6. Record-keeping requirements What records must be kept, for how long (7 years), and where they are stored. Staff should understand that records must be accessible and that they cannot be deleted.

7. Consequences of non-compliance The penalties for failing to meet obligations — both for the agency and for individuals. This matters for motivating genuine compliance rather than box-ticking.

8. Real estate-specific risks and red flags AML risks that are specific to your sector. AUSTRAC has published risk insights for real estate that cover the indicators most relevant to agents. Staff should know these specifically.

Frequency: initial and ongoing

Initial training must happen before a staff member performs any AML-relevant duty. For existing staff, this means before 1 July 2026. For new staff joining after that date, it means before they take on any compliance-related work.

Ongoing training must happen at least annually. This keeps staff current as regulatory guidance evolves, as new risk indicators are published, and as your agency's own risk profile changes.

Ongoing training does not need to be as comprehensive as initial training each year. A focused refresher covering what has changed — new AUSTRAC guidance, lessons from the past year's transactions, updates to your program — is sufficient.

What training records must contain

Your training records must be able to show:

Who was trained (full name, role)
When training occurred (date)
What was covered (the training content or curriculum)
How it was delivered (in-platform, in-person session, external provider)

A sign-in sheet from a team meeting with no detail of what was covered is not an adequate training record. Your records should be specific enough that an AUSTRAC assessor could determine that training was substantive.

Records must be retained for 7 years from the date of training. Source: AML/CTF Act 2006, s 107.

One practical approach for a small agency

For a small agency with 3–8 staff:

Week 1: The principal (Compliance Officer) completes training first and gains a solid understanding of the obligations. This prepares them to answer questions from the rest of the team.

Week 1–2: All sales staff complete training — in-platform or in a group session. Document who attended and what was covered.

Week 2: Administrative staff and anyone else with an AML-relevant role complete training.

Ongoing: Build an annual refresher into your calendar. Each August (after the July 1 anniversary), run a 1-hour refresher covering any guidance updates from AUSTRAC and your own agency's experiences from the past year.

A note on the Compliance Officer's training

The Compliance Officer has a deeper responsibility than general risk awareness. They are accountable for the program — for CDD oversight, SMR decisions, the Annual Compliance Report, and notifying AUSTRAC of changes.

The Compliance Officer should have a working understanding of the obligations, not just the risk awareness training. AUSTRAC's guidance, the Program Starter Kit documentation, and the compliance-kb.md in AML Simple are good starting points. For a more structured approach, consider a session with a qualified AML/CTF compliance professional.

For the full compliance picture, read the complete AUSTRAC Tranche 2 guide for real estate agencies. For your week-by-week action plan, see Your AML compliance timeline for real estate agencies.

This content is general information only and does not constitute legal or AML/CTF advice. For tailored advice, consult a licensed AML/CTF advisor. AML Simple is a compliance tool, not a law firm.

Want a personalised Tranche 2 readiness score for your agency? Take the free 5-minute Readiness Check → amlsimple.com/check