Your AML compliance checklist for July 2026

This post is a reference checklist — a single place to see all of your AML/CTF obligations as a real estate agency and confirm where you stand.

It covers two categories: the six preparation tasks you need to complete before 1 July 2026, and the thirteen ongoing obligations that apply from that date forward. Work through it alongside your program document, not instead of it.

First: confirm your agency is in scope

AML/CTF obligations apply to agencies providing designated services — specifically, brokering the purchase, sale, or transfer of real estate. If your agency facilitates property sales or purchases, you are in scope.

Property management only? If your agency only manages rental properties and does not broker sales, the Tranche 2 reforms do not currently apply to you. Your obligations differ from sales agencies.

If you are in scope, the checklist below applies to you.

Part 1: Preparation tasks (complete before 1 July 2026)

These six tasks must be in place before your ongoing obligations begin.

Task	What it involves	Deadline
1. Enrol with AUSTRAC	Register your agency as a reporting entity via AUSTRAC Online. Provide ABN, business details, and designated services provided.	By 29 July 2026 (enrolment opens 31 March 2026)
2. Conduct your ML/TF/PF risk assessment	Assess money laundering, terrorism financing, and proliferation financing risks across your customers, services, delivery channels, and geographic locations. Document and sign off at senior management level.	Before 1 July 2026
3. Develop your AML/CTF program	Build a documented program covering CDD procedures, reporting obligations, record keeping, staff training, governance, and employee due diligence. Must be calibrated to your risk assessment.	Before 1 July 2026
4. Appoint your compliance officer	Appoint a fit-and-proper person at senior management level as your AML/CTF compliance officer. Document the appointment in your program.	Before 1 July 2026 (notify AUSTRAC by 29 July 2026)
5. Implement employee due diligence	Establish and document a process for vetting staff who perform AML-relevant duties, proportionate to the risk of their role.	Before 1 July 2026
6. Train your staff	Provide AML/CTF risk awareness training to all staff performing AML-relevant duties before they start those duties. Document who was trained, when, and what was covered. Training records must be kept for seven years.	Before staff perform AML-relevant duties (before 1 July 2026 for existing staff)

Source: AML/CTF Act 2006; AUSTRAC Real Estate Guidance·As of March 2026

Part 2: Ongoing obligations (from 1 July 2026)

From 1 July 2026, these thirteen obligations apply to every relevant transaction your agency conducts.

Customer due diligence (CDD)

Obligation	What it requires
7. Initial CDD	Before providing a designated service to any customer: collect their full legal name, date of birth, and residential address; verify their identity using a reliable and independent method (physical inspection of ID, video call, DVS, or accredited electronic verification); identify whether they are acting for another party (if so, identify that party too).
8. Ongoing CDD	Monitor clients throughout the transaction to identify, assess, and manage ML/TF risks over time. Update client information if circumstances change. Stay alert to new red flags.
9. Enhanced CDD (when triggered)	Apply additional scrutiny when any trigger is present: the customer is a foreign PEP, an SMR has been or will be filed, your risk assessment rates them as high risk, or the transaction involves a high-risk jurisdiction or complex ownership structure. Enhanced CDD requires senior management approval, deeper verification, and source of funds/wealth checks.
10. Simplified CDD (where applicable)	For customers your risk assessment identifies as genuinely low risk, a lighter verification approach may apply. Simplified CDD is not an exemption — you must still collect all required information. Whether it applies is determined by your program and risk assessment, not ad hoc for individual clients.

Source: AML/CTF Act 2006·As of March 2026

Screening obligations

Obligation	What it requires
11. Sanctions screening	Screen each customer against the DFAT Consolidated List (Australian autonomous sanctions) and the UN consolidated list. You cannot deal with a sanctioned person or entity. Screening must occur before or at the time of providing a designated service.
12. PEP screening	Identify whether a customer is a Politically Exposed Person (senior government official, politician, judge, military officer, or state-owned enterprise executive) or their family or close associate. Foreign PEPs automatically trigger Enhanced CDD.
13. Beneficial ownership identification	For company or trust clients, identify any individual with 25% or more ownership interest or effective control. If you cannot identify the beneficial owner, consider whether Enhanced CDD is required.

Source: AML/CTF Act 2006; DFAT Consolidated List·As of March 2026

Reporting obligations

Obligation	What it requires	Timeframe
14. Suspicious Matter Reports (SMRs)	File an SMR with AUSTRAC when you form a suspicion that a matter relates to money laundering, terrorism financing, or proceeds of crime. Important: it is a criminal offence to tell a client that an SMR has been or will be filed (tipping-off offence).	Within 24 hours (terrorism financing); within 3 business days (other suspicious activity)
15. Threshold Transaction Reports (TTRs)	File a TTR with AUSTRAC when a transaction involves physical currency of A$10,000 or more (or foreign equivalent). Includes situations where a customer deliberately breaks up a transaction to avoid the threshold (structuring — itself an offence).	Within 10 business days of the transaction

Source: AML/CTF Act 2006, ss 41, 45, 47·As of March 2026

Record keeping and ongoing compliance

Obligation	What it requires
16. Record keeping (7 years)	Retain all AML/CTF records — CDD information, transaction records, SMRs, TTRs, training records, risk assessments, and program documentation — for a minimum of seven years. Records must be retrievable on request from AUSTRAC.
17. Annual Compliance Report	Lodge an Annual Compliance Report with AUSTRAC each year between 1 January and 31 March. The first report covers the period 1 July to 31 December 2026, due by 31 March 2027. It summarises compliance activities, training conducted, program changes, and SMRs and TTRs filed.
18. Independent evaluation	Your AML/CTF program must be independently evaluated at regular intervals. The first evaluation for newly regulated entities is due around 2030–2032. Frequency depends on the size and complexity of your business.
19. Update AUSTRAC enrolment (within 14 days)	Notify AUSTRAC within 14 days of any change to your business details — including a change of compliance officer, business address, or designated services provided.

Source: AML/CTF Act 2006·As of March 2026

Key dates at a glance

Date	Milestone
31 March 2026	AUSTRAC enrolment opens
1 July 2026	AML/CTF obligations commence — all ongoing obligations apply from this date
29 July 2026	AUSTRAC enrolment deadline; compliance officer details must be notified
31 March 2027	First Annual Compliance Report due (covering 1 July to 31 December 2026)
2030–2032	First independent program evaluations due

Source: AUSTRAC Guidance·As of March 2026

Using this checklist

This is a reference, not a compliance guarantee. Use it to:

Confirm you have considered each obligation
Identify gaps in your preparation
Track progress alongside your program documentation

For a step-by-step first-week plan, see: Your first week of AML compliance — what to do and in what order

For CDD specifically, see: Customer due diligence for real estate: a plain-English guide

For enrolling with AUSTRAC, see: How to enrol with AUSTRAC as a real estate agency

58 days until obligations commence

1 July 2026

AML Simple guides you through each obligation — start free

From risk assessment to CDD to ongoing monitoring, AML Simple helps you build and run your compliance program in a structured workflow. Compliance workflow tool — not professional advice.

Get AUSTRAC ready

About AML Simple: AML Simple is a compliance workflow tool, not a provider of legal or regulatory advice. This post is a general educational reference based on the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and AUSTRAC guidance. It does not constitute compliance advice and is not a substitute for professional guidance specific to your circumstances. Completing each item on this checklist is a starting point — it does not guarantee your agency is compliant. Every agency's obligations may differ depending on their business structure, size, and the services they provide. Always consult a qualified AML/CTF compliance professional for advice tailored to your agency. AUSTRAC's guidance and legislation take precedence over any description in this post — always check primary sources.