Your AML compliance tool doesn't have to come from your CRM
From July 2026, Australian real estate agencies must meet AUSTRAC's Tranche 2 AML/CTF obligations. You don't need to wait for your CRM to add compliance features — a standalone tool works with whatever software you already use.
Your AML compliance tool doesn't have to come from your CRM
The fastest way to meet your AUSTRAC obligations before 1 July 2026 is to sign up for AML Simple, connect nothing, and get your AML/CTF program running in about 15 minutes — regardless of what software you use to run your agency.
You do not need a new CRM. You do not need to wait for your current CRM to add a compliance feature. Your CRM and your AML compliance tool can be two separate things, and for most Australian agencies, that is already the sensible default.
Here is why that matters, and what your actual obligations are.
What AUSTRAC actually requires from 1 July 2026
From 1 July 2026, every real estate agency that brokers property sales in Australia must comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (as amended by the AML/CTF Amendment Act 2024). The core obligations are:
- Enrol with AUSTRAC (enrolment deadline 29 July 2026)
- Develop and maintain an AML/CTF program — a documented risk assessment, policies, and procedures tailored to your agency
- Appoint a compliance officer at senior management level
- Conduct customer due diligence (CDD) on clients before providing designated services — identity verification, PEP and sanctions screening
- Train staff on AML/CTF risks
- Submit Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs) when triggered
- Submit an Annual Compliance Report (first reporting period: 1 January – 31 March 2027)
- Keep records for at least seven years
None of these obligations require a specific CRM. None of them require any software at all — you could, in principle, do all of it on paper. In practice, software makes it manageable.
For a full explanation of what each obligation involves, see: Your AML/CTF Program: A Complete Guide
The fastest path: AML Simple, starting now
Whether you are on PropertyMe, Rex, Console, Agentbox, VaultRE, or no CRM at all, the steps inside AML Simple are the same:
- Sign up — around 2 minutes. Enter your ABN and your business details are pulled from the ABR automatically.
- AUSTRAC Enrolment Cheat Sheet (
/enrolment-cheatsheet) — around 5 minutes. Open AUSTRAC Connect in one tab, open the Cheat Sheet in another. Every field AUSTRAC needs is pre-filled from your account details. Copy-paste down the form. - AML/CTF Program Generator (
/program/generate) — around 15 minutes. The wizard asks questions about your agency — services offered, transaction volumes, client risk profile — and generates your AML/CTF program document, consistent with the structure AUSTRAC recommends in their Program Starter Kit.
From there, your ongoing workflow sits inside AML Simple: add clients, send identity verification links, run sanctions screening, log staff training, and draft SMRs when needed. Your CRM stays exactly as it is.
AML Simple is a compliance workflow tool, not legal advice. If you need an expert to review your program or advise on edge cases, we can connect you with a qualified AML professional from A$199/session.
Who this is for
This approach works for any agency that:
- Uses an independent or non-AML-bundled CRM for their day-to-day operations
- Has not received a specific offer from their CRM provider to include AML/CTF compliance as part of their existing subscription
- Wants to get compliant before the deadline without changing their current agency software
If your CRM has announced a fully built AML/CTF compliance module — covering your AML/CTF program, CDD, sanctions screening, SMR filing, TTR tracking, training records, and annual reporting — evaluate that offer on its merits. The question to ask is whether it covers all of your obligations, not just identity verification.
If it doesn't cover all of them, you'll still need a standalone solution for the rest. See: Can my CRM handle AUSTRAC Tranche 2?
What "CRM-bundled AML" usually means in practice
A number of software providers in the Australian real estate market have begun adding identity verification or compliance-adjacent features to their platforms.
The important distinction is between identity verification (one step of customer due diligence) and a full AML/CTF program (the complete set of obligations AUSTRAC requires).
AUSTRAC requires all of the following — not just identity checks:
| Obligation | Identity verification alone? |
|---|---|
| AML/CTF program document | No |
| Risk assessment | No |
| Staff training records | No |
| SMR drafting and filing | No |
| Threshold transaction reporting | No |
| Annual Compliance Report | No |
| 7-year record keeping | No |
| Customer due diligence (CDD) | Partially — IDV is one component of CDD |
| Sanctions screening | No |
If the feature your CRM is adding covers only identity verification, you will still need to build and maintain the rest of your AML/CTF program separately.
Prefer to do it yourself? Here is what is involved
The same steps AML Simple handles for you can be done manually. AUSTRAC's Program Starter Kit provides templates for small real estate agencies. You would:
- Complete the risk assessment template — assess your exposure across your client types, services, and geographies
- Draft an AML/CTF policy and procedures document based on that risk assessment
- Appoint and document your compliance officer
- Build a staff training program and keep records of completion
- Set up a process for collecting and verifying client identity documents, checking against PEP and sanctions lists
- Set up a process for identifying and reporting suspicious matters and threshold transactions
- Schedule your Annual Compliance Report for the first reporting period
This typically takes 20–40 hours to do properly from scratch. AML Simple handles the program generation, guided CDD workflow, sanctions screening, and record-keeping — the parts that benefit most from structured software. You still make all the compliance decisions; we handle the workflow.
No lock-in, no CRM dependency
AML Simple has no commercial agreement with any CRM provider. We are not affiliated with, endorsed by, or partnered with any property management or real estate CRM.
Your compliance data stays in Australia (Sydney, AWS ap-southeast-2). You can export your records at any time. If you switch CRMs tomorrow, your compliance program is unaffected.
Foundation tier is free, up to five clients. Paid plans start from A$79/month. All paid plans include a 14-day free trial.
AML Simple is a compliance workflow tool, not a source of legal advice. This article provides general information about AUSTRAC's Tranche 2 requirements. For advice specific to your agency, consult a qualified AML compliance professional.
Sources: Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), as amended by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth). legislation.gov.au. AUSTRAC, Real Estate Program Starter Kit, austrac.gov.au. AUSTRAC AML/CTF obligations summary: AML/CTF Act 2006, Parts 2, 3, 4, 7 and Schedule 1. Seven-year record-keeping: s 112.