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What your existing AML tool actually covers — and what it doesn't

If your agency uses InfoTrack, PEXA Clear, or Reapit Verify, you may assume you're covered for AUSTRAC Tranche 2. Here's exactly what each tool does and doesn't cover — and what to do if there are gaps.

By AML Simple Team

If your agency already uses InfoTrack, PEXA Clear, or Reapit Verify, you've probably noticed they now include an AML compliance feature. It's a reasonable assumption that using the AML tool inside a platform you already pay for might cover your AUSTRAC obligations.

This post breaks down exactly what each tool covers, what AUSTRAC actually requires, and what questions to ask before assuming you're sorted. If you find gaps after reading this — AML Simple works standalone alongside any of these platforms, covering the obligations they leave out.

Disclaimer: This article describes AUSTRAC's AML/CTF Program obligations based on publicly available legislative sources. It does not constitute legal or compliance advice. Whether your specific compliance setup is adequate is a question for a qualified AML professional. AML Simple is a workflow tool, not an advice service.


What AUSTRAC actually requires

Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (as amended in 2024), every real estate agency that brokers property sales must build and maintain a full AML/CTF compliance program from 1 July 2026. AUSTRAC's own Real Estate Program Starter Kit breaks this into ten areas:

  1. AML/CTF Program document — a documented, risk-based program covering governance, due diligence, and compliance responsibilities (ss 26C–26F)
  2. ML/TF/PF Risk Assessment — covering customers, services, delivery channels, and geography (s 26D)
  3. Customer Due Diligence (CDD) — initial, ongoing, enhanced, and simplified; includes beneficial ownership (ss 28–30)
  4. Customer identification and verification
  5. PEP and sanctions screening (s 26F; Autonomous Sanctions Act 2011)
  6. Staff training with records of completion (s 26F(4)(e))
  7. Suspicious Matter Reports (SMRs) — filed within 24 hours for terrorism financing; 3 business days for money laundering (s 41)
  8. Transaction Threshold Reports (TTRs) — cash transactions of A$10,000+, within 10 business days (s 43)
  9. Ongoing monitoring — continuing due diligence for existing clients (ss 30, 36)
  10. AUSTRAC enrolment, Annual Compliance Report, and Independent Evaluation — enrolment by 29 July 2026; first ACR due 31 March 2027 (s 51B; s 47; s 26F)

This is the full picture. Now let's look at what each tool actually covers.


InfoTrack AML/CTF compliance centre

Short answer: Comprehensive platform — covers all 10 obligations.

InfoTrack launched its AML/CTF Compliance Centre on 30 March 2026, built in partnership with Grant Thornton. Based on its public product pages, it covers the full obligation stack: program generation, risk assessment, CDD workflows, identity verification (registered DVS provider), PEP and sanctions screening, CPD-accredited in-platform staff training, direct SMR and TTR filing to AUSTRAC, ongoing monitoring, and Annual Compliance Report generation with 7-year automated record retention.

If your agency already uses InfoTrack, the compliance centre is a substantive tool — not a verification add-on. Platform access is free; you pay per identity verification search. One point to check: InfoTrack's primary design context is legal and conveyancing practice. Real estate agencies are a Tranche 2 expansion audience, so the workflow reflects that background. Confirm it suits how your RE team actually works day-to-day.


PEXA Clear

Short answer: Strong transaction-level tool — covers approximately 4 of 10 obligations.

PEXA Clear is built on FrankieOne technology and positions itself as "beyond ID verification." For individual transactions, that's accurate — it combines identity verification, KYB, and PEP/sanctions/adverse media screening with per-transaction risk scoring.

But PEXA Clear operates at the transaction level, not at the program level AUSTRAC requires. Based on its public product pages, the following obligations are not covered:

  • AML/CTF Program document — no mention on any public source
  • Staff training — external REIQ partnership only; no in-platform training module
  • SMR filing — PEXA Clear provides guidance on when to escalate but does not draft or file reports
  • TTR tracking — not referenced anywhere
  • Ongoing post-settlement monitoring — monitoring is scoped to active transactions only

Agencies relying on PEXA Clear still need to address their program document, staff training, SMR filing, cash transaction reporting, and annual compliance reporting separately.

On cost: PEXA Clear charges A$40–65 per transaction. An agency completing 10 transactions per month pays A$400–650/month in verification costs alone — before any supplementary compliance tool.


Reapit Verify

Short answer: CRM-integrated CDD tool — covers approximately 4–5 of 10 obligations, Reapit customers only.

Reapit Verify is built into the Reapit Sales CRM and describes itself as an "end-to-end AML solution." That claim refers to end-to-end within the Reapit workflow — not end-to-end coverage of all AUSTRAC obligations.

Confirmed from Reapit's public pages: CDD workflows (automated KYC/KYB), identity verification (registered DVS provider), transaction risk scoring, and SMR generation. These are meaningful capabilities.

What Reapit Verify does not confirm:

  • AML/CTF Program generation — not mentioned on the product page
  • PEP and sanctions screening — absent from all reviewed sources (a notable gap to verify directly)
  • Staff training — external partnership only; no in-platform module confirmed
  • TTR tracking — not referenced

Reapit Verify is also not a standalone product. It is only available to existing Reapit CRM customers. For a full comparison of how AML Simple works alongside Reapit, see: Your AML compliance tool doesn't have to come from your CRM


At a glance

ObligationInfoTrackPEXA ClearReapit Verify
AML/CTF Program generation
Risk assessment⚠️ Transaction only
CDD workflows
Identity verification
PEP and sanctions screening❓ Unconfirmed
Staff training (in-platform)✅ CPD-accredited❌ External only❌ External only
SMR drafting and filing⚠️ Guidance only
TTR tracking
Ongoing monitoring⚠️ Transaction scope⚠️ Partial
Annual Compliance Report⚠️ Audit trail only⚠️ Audit trail only
Confirmed obligations (of 10)10/10~4/10~4–5/10

✅ Confirmed covered | ⚠️ Partial | ❓ Unconfirmed | ❌ Confirmed absent

Coverage based on each tool's public product pages as at April 2026. Verify directly with your provider before relying on this for compliance purposes.


What this means for your agency

If you use InfoTrack, the compliance centre covers the full obligation set. Check that the workflow suits your RE team's practice — it was designed first for legal and conveyancing firms.

If you use PEXA Clear or Reapit Verify, these tools handle verification and CDD well. But they are not complete compliance platforms. You still need to address your AML/CTF Program document, staff training, SMR filing, TTR reporting, and ongoing client monitoring through another route.

AML Simple works alongside any of these tools — no integration required. Use it to cover the obligations your current tool leaves out. Foundation tier is free. Plans from A$79/month, all free until 1 July 2026.

Start free with AML Simple Foundation — no credit card required, up to 5 clients.


For the complete guide to AML obligations under Tranche 2, see: Your AML/CTF Program: A Complete Guide


Need advice on whether your specific compliance setup is adequate for your obligations? AML Simple offers expert advisory sessions from A$199 if you need a professional opinion. This article is general information only and does not constitute legal or compliance advice.

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