A completed AML program: worked example for a 5-person agency

Most guides explain what an AML/CTF program needs to contain. Almost none show you what one actually looks like when it's done.

This post fills that gap. Below is a worked example - a hypothetical completed AML/CTF program for a realistic 5-person residential real estate agency. It follows the AUSTRAC Program Starter Kit structure and shows the decisions a real agency would make for each section.

Read it as a reference. Your program will have different details - different risk factors, different staff, different circumstances. But the structure and the type of content required will look similar.

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The agency: Coastal Property Pty Ltd

Business: Residential real estate agency, Brisbane south side (QLD) Designated service: Brokering the purchase, sale, and transfer of residential real estate Staff: 5 people (see below) Enrolled with AUSTRAC: April 2026 (after enrolment opened 31 March 2026) Program status: Adopted by senior management, May 2026

Staff and AML roles:

A note on Tom: Tom is excluded from AML obligations because property management is not a designated service under the AML/CTF Act 2006. If Tom were to assist with property sales transactions, that would change - he would then be performing AML-relevant duties and would need to be trained and covered by the program.

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Section 1: ML/TF/PF risk assessment

The risk assessment is the foundation of the program. It documents Coastal Property's money laundering, terrorism financing, and proliferation financing (ML/TF/PF) risks across the four categories required by AUSTRAC, and shows what controls reduce those risks.

Assessment methodology: 3x3 risk matrix (likelihood x impact). Inherent risk rated before controls; residual risk rated after controls.

Customers

Current client base assessment: Coastal Property's clients are predominantly local Queensland owner-occupiers and local investors. The agency has not dealt with any known politically exposed persons (PEPs) or foreign nationals in the past 12 months. Interstate buyers represent approximately 15% of buyer clients.

Services

No unfinanced (all-cash) purchases have occurred in the past 12 months. The agency notes this as a risk indicator to monitor.

Delivery channels

Geographic locations

Overall residual risk: LOW to MEDIUM-LOW. The agency's primary risk is from interstate or remote buyers. All other risk categories are low given the local, largely financed nature of the client base.

Sign-off: Sarah Mitchell (Principal), dated 1 May 2026. Review due: 1 May 2027, or sooner if the business changes (new services, new markets, new staff structures) or if regulatory requirements are updated.

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Section 2: Compliance officer appointment

Name: Sarah Mitchell Position: Principal, Coastal Property Pty Ltd Appointed: 1 May 2026 AUSTRAC notified: 15 May 2026 (before the 29 July 2026 deadline)

Why Sarah? As principal, Sarah has the authority to make compliance decisions and allocate resources - the two things a compliance officer needs to be effective. The AML/CTF Act requires the compliance officer to be at senior management level and to be "fit and proper" to carry out the role. No specific AML qualification is required, but the person must be capable of understanding the agency's obligations and have the standing to act on them.

Sarah's responsibilities under this program:

• Maintain and update the AML/CTF program
• Review CDD records completed by agents (weekly review each Monday)
• Ensure all staff complete initial and annual training
• Make decisions on suspicious matters and file SMRs when required
• Oversee sanctions and PEP screening
• Notify AUSTRAC of any changes to the business within 14 days
• Lodge the Annual Compliance Report between 1 January and 31 March each year

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Section 3: CDD procedure - worked example

Here is how Coastal Property completes CDD for a typical buyer client.

Scenario: John Chen is purchasing a residential property at 14 Maple Street, Yeronga QLD for A$650,000. He is a local Brisbane buyer, purchasing as an investment property with bank finance.

Step 1: Collect client information

James (the agent) collects the following at the first meeting:

• Full legal name: John Wei Chen
• Date of birth: 15 April 1982
• Residential address: 12 Park Avenue, Newstead QLD 4006
• Acting on own behalf? Confirmed yes - no representative, purchasing in his own name
• Nature and purpose of the transaction: Purchasing residential investment property at 14 Maple St, Yeronga. Funding source: bank mortgage with ANZ.

Step 2: Identity verification

James inspects John's Queensland driver's licence at the open home on 10 March 2026. He confirms the photo matches John.

Document recorded:

• Type: Australian driver's licence
• Number: 023456789
• Issuer: Queensland Department of Transport and Main Roads
• Expiry: 15 April 2027
• Verified by: James Kowalski, 10 March 2026, method: in-person document inspection

Step 3: Beneficial ownership check

John is buying in his personal name. No company or trust structure is involved. Beneficial ownership identification is not required.

If John were buying through a company or trust, the agent would identify any individual with 25% or more ownership or effective control before proceeding.

Step 4: Sanctions and PEP screening

Before proceeding, James screens John against:

• DFAT Consolidated List (Australian and UN sanctions): no match
• PEP assessment: John is determined not to be a politically exposed person (foreign or domestic) based on information collected and publicly available information.

Screening recorded: screened by James Kowalski, 10 March 2026. Result: no match. Record retained in the CDD file for John Chen.

Step 5: Risk rating

Overall risk rating: LOW

Rationale: Local Brisbane buyer, financed purchase, standard identity document (QLD driver's licence), met in person, no suspicious indicators, no PEP or sanctions flags.

No enhanced CDD required. Standard ongoing monitoring applies.

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Section 4: Staff training

Initial training delivered: 15 March 2026

Delivered by: Sarah Mitchell (Principal / Compliance Officer)

Format: One-hour briefing session covering:

1. What the AML/CTF Act requires and why real estate is now regulated
2. What a designated service is - and that property management is not one
3. CDD procedure - what to collect, how to verify, when to ask more questions
4. How to identify red flags and suspicious activity
5. How to escalate concerns to Sarah
6. SMR and TTR procedures - including the tipping-off offence (it is a criminal offence to tell a client an SMR has been filed)
7. Record-keeping requirements - what to retain and for how long
8. Consequences of non-compliance for the agency and for individuals

Staff trained:

• James Kowalski (sales agent) - attended 15 March 2026
• Priya Nair (sales agent) - attended 15 March 2026
• Bec Huang (admin) - attended 15 March 2026

Tom Ferreira (property manager) was not included - he does not perform AML-relevant duties.

Training records: Attendance sheet signed by each participant, retained in the agency's AML/CTF program file.

Annual refresher: Scheduled for March 2027. Sarah will update content to reflect any regulatory or program changes since the initial session.

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Section 5: Ongoing monitoring and reporting

Weekly compliance review

Each Monday morning, Sarah reviews:

• CDD files completed by agents in the previous week
• Any screening results not yet signed off
• Any open client matters where CDD has not been completed

This review typically takes 20-30 minutes for a five-person agency.

Sanctions list monitoring

The agency uses AML Simple's automated alert system to be notified when the DFAT Consolidated List is updated. When an update occurs, all active clients are re-screened before the next transaction with that client.

Suspicious matter escalation procedure

If an agent identifies a potential red flag (for example, a client refuses to provide ID, requests deposit payment to an unrelated third party, or makes a cash offer with no apparent source of funds), the agent:

1. Does not confront the client
2. Immediately escalates to Sarah by phone or in person
3. Documents the concern in the client's file

Sarah then assesses the matter and, if she has reasonable grounds for suspicion, lodges an SMR with AUSTRAC:

• Terrorism financing suspicion: SMR must be lodged within 24 hours
• Money laundering or other: SMR must be lodged within 3 business days

The tipping-off offence means the agency must not disclose to the client that an SMR has been or may be filed. This applies to everyone at the agency - not just Sarah.

Threshold Transaction Reports (TTRs)

Cash transactions of A$10,000 or more (or foreign currency equivalent) must be reported to AUSTRAC within 10 business days. Coastal Property has not received any cash at this threshold. If they did, Sarah would file a TTR via AUSTRAC Online.

Annual Compliance Report

The first Annual Compliance Report covers 1 July to 31 December 2026. It must be lodged with AUSTRAC by 31 March 2027. Sarah has set a calendar reminder for 15 January 2027 to begin preparing the report.

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What this example shows you

A completed AML/CTF program for a small residential agency is not as complicated as it might sound. The core of it is:

1. A documented risk assessment that reflects your agency's actual client base and operating model
2. A compliance officer with genuine authority and clear responsibilities
3. A CDD checklist your agents can follow for every client
4. A training session that happened before July 2026, with records kept
5. A weekly review habit and a clear escalation path for anything suspicious

The AUSTRAC Program Starter Kit gives you pre-populated Word documents to start from. AML Simple walks you through the same content in a structured workflow - and keeps your records, screening results, and audit trail in one place.

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Sources

• AML/CTF Act 2006: https://www.legislation.gov.au/C2006A00169/latest/text
• AUSTRAC Real Estate Program Starter Kit: https://www.austrac.gov.au/reforms/sector-specific-guidance/real-estate-guidance/real-estate-program-starter-kit
• AUSTRAC Initial CDD for individuals (Reform): https://www.austrac.gov.au/amlctf-reform/reforms-guidance/amlctf-program-reform/customer-due-diligence-reform/initial-customer-due-diligence-reform/initial-customer-due-diligence-guides-customer-type-reform/initial-cdd-individuals-reform
• DFAT Consolidated List: https://www.dfat.gov.au/international-relations/security/sanctions/consolidated-list