Your first week of AML compliance — what to do and in what order

You've decided to get started. Maybe you read that the deadline is 1 July 2026. Maybe a colleague asked whether you had your program sorted yet. Either way, you're here, and you want to know what to actually do — not another explainer on what AML means, but a practical first-week plan.

This post gives you that plan: what to tackle each day, in an order that makes sense, with the most important things first.

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First: is your agency in scope?

Before spending a week on compliance, confirm that your agency actually has obligations under the new laws.

The AML/CTF Act applies to agencies providing designated services — specifically, brokering the purchase, sale, or transfer of real estate. If your agency is involved in property transactions (as a buyer's agent, seller's agent, or both), you are a reporting entity with obligations from 1 July 2026.

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

If you are in scope — and most sales agencies are — read on.

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Day 1: Understand your obligations and read the AUSTRAC guidance

Before building anything, spend time understanding what you are actually required to do.

AUSTRAC has published a Real Estate Program Starter Kit specifically for agencies with 15 or fewer personnel providing one designated service. If that describes your agency, start there — it is the most practical resource AUSTRAC offers, and it covers every required component.

What to do today:

• Download the AUSTRAC Program Starter Kit
• Read the overview of the 19 obligations (pre-July preparation + ongoing from 1 July)
• Note the key dates: enrolment opens 31 March 2026, enrolment deadline 29 July 2026, obligations commence 1 July 2026
• Identify who in your agency will take on the compliance officer role (more on this below)

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Day 2: Conduct your ML/TF/PF risk assessment

The risk assessment is the foundation of everything. Before you can build your program, you need to understand the money laundering, terrorism financing, and proliferation financing (ML/TF/PF) risks that apply to your agency specifically.

The AUSTRAC Starter Kit includes a pre-populated risk assessment template in Word format. It covers the four required categories:

• Your customers — who are they? Any non-residents, overseas buyers, or high-net-worth individuals?
• Your services — what property transactions do you facilitate? Any off-market or cash-heavy deals?
• Your delivery channels — do you meet clients in person or deal with remote buyers sight-unseen?
• Geographic location — where do your clients and their funds come from?

For each category, you rate the likelihood and impact of risk, factor in existing controls, and arrive at a residual risk level. The completed assessment must be approved by senior management.

What to do today:

• Open the risk assessment template from the AUSTRAC Starter Kit
• Work through each section with your knowledge of your agency's business
• Document your responses — even brief notes are better than blank fields
• Note any areas where you need more information or are unsure

You do not need to finalise the risk assessment today. Getting a solid draft on Day 2 gives you what you need to move forward. You can refine it as you build your program.

AML Simple guides you through your risk assessment — start free →

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Day 3: Appoint your compliance officer

Your AML/CTF program must have a nominated compliance officer at senior management level. This is a legal requirement, and AUSTRAC must be notified of their details by 29 July 2026.

In a small agency, the compliance officer is almost always the principal. In larger agencies, it might be the operations manager or a senior agent with the authority to make decisions and allocate resources. The key requirement is seniority and the ability to act.

The compliance officer role carries real legal responsibilities. This person is responsible for implementing and managing the program, overseeing day-to-day CDD, ensuring reports are filed on time, and keeping the program up to date.

What to do today:

• Decide who the compliance officer will be (principal is the most common choice in small agencies)
• Document the appointment in your program (even a signed memo is sufficient at this stage)
• Note that you will need to notify AUSTRAC of this person's details when you enrol — keep their full name and contact details ready

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Day 4: Enrol with AUSTRAC

Enrolment registers your agency as a reporting entity with AUSTRAC. You will need:

• Your agency's ABN and business details
• The compliance officer's details (name and contact information)
• Details of the designated services your agency provides

The enrolment process is completed through AUSTRAC Online. It is not complex, but it is time-sensitive — enrol as soon as it opens if you have not already.

What to do today:

• If enrolment is open (from 31 March 2026), complete your enrolment via AUSTRAC Online
• If it is not yet open, set a calendar reminder for 31 March to complete enrolment that day
• Keep a record of your enrolment confirmation

For a step-by-step walkthrough of the enrolment process, see our post: How to enrol with AUSTRAC as a real estate agency.

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Day 5: Build your AML/CTF program framework

With your risk assessment drafted and your compliance officer appointed, Day 5 is about turning those inputs into a program document — the written framework that governs how your agency manages AML/CTF obligations day to day.

Your program must cover:

• Customer due diligence (CDD): How you identify clients and verify their identity before providing a designated service
• Ongoing monitoring: How you stay alert to changes in client risk throughout a transaction
• Suspicious Matter Reports (SMRs): How to identify, escalate, and file suspicious activity reports
• Threshold Transaction Reports (TTRs): How to identify and report cash transactions of A$10,000 or more
• Record keeping: How you retain records for the required seven-year minimum
• Staff training: How you will train your team and track training completion
• Governance: How senior management oversees ML/TF/PF risk

The AUSTRAC Starter Kit includes Word templates for each of these. For most small agencies, the work is customisation — adapting the pre-populated templates to your actual procedures — rather than writing from scratch.

What to do today:

• Open the program templates from the AUSTRAC Starter Kit
• Work through the CDD and reporting sections — these are the most critical
• Note any areas where your agency's procedures differ from the default template
• Do not aim for a finished product today — a working draft is the goal

AML Simple's program generator guides you through each component — start building →

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Week 2: Train your staff

The Act requires all staff who perform AML-relevant duties to receive AML/CTF risk awareness training before they start those duties. For most agencies, this means your agents and support staff need at least a foundational briefing before 1 July 2026.

Training must cover:

• What the AML/CTF Act requires and why it applies to real estate
• How to identify suspicious behaviour and real estate-specific red flags
• How to escalate concerns to the compliance officer
• CDD procedures — what information to collect and how to verify it
• The tipping-off offence (a criminal offence to tell a client an SMR has been or will be filed)

Training records — who was trained, when, and what was covered — must be kept for seven years.

Week 2 plan:

• Deliver a one-hour briefing for all relevant staff
• Document attendance (name, date, topics covered)
• Schedule annual refreshers in the calendar

A small agency with three agents can run a single morning session. You do not need a formal training package — a structured walkthrough of the program with Q&A is sufficient at this stage, provided you document it.

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After week 2: set up your ongoing routines

Once your program is in place and your team is briefed, the preparation phase is largely complete. What follows is ongoing compliance from 1 July 2026:

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Where AML Simple fits in

AML Simple is a compliance workflow tool that guides you through each of these steps — risk assessment, program generation, CDD, client screening, and record keeping. It does not replace professional advice, but it helps you build and run your compliance processes in a structured, documented way.

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