AML Compliance Guide
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Deadline: 29 July 2026 — enforcement now active

Compliance officer for Real estate agents — 2026 AUSTRAC Guide

If your real estate business will provide a designated service from 1 July 2026, you need to put someone in charge of AML/CTF compliance straight away. For a small agency, that means choosing the person who will own enrolment, customer checks, sanctions screening, reporting and staff training across your property sales work. If nobody is clearly responsible and deadlines are missed, AUSTRAC can take enforcement action, with civil penalties up to $33.5 million per contravention and criminal penalties for intentional breaches.

Your AML/CTF obligations

  1. 1. AUSTRAC enrolment
  2. 2. Compliance officer
  3. 3. ML/TF risk assessment
  4. 4. AML/CTF program
  5. 5. Customer due diligence
  6. 6. Sanctions screening
  7. 7. Suspicious matter reporting
  8. 8. Record keeping (7 years)
  9. 9. Staff training

For a real estate agency, the compliance officer is the person who makes sure your AML/CTF obligations actually happen in day-to-day practice. This is not a separate licence and AUSTRAC does not appoint the person for you. In a small office it is often the principal, licensee, director or senior manager. What matters is that the person has enough authority to set procedures, require staff to collect identification, stop a transaction from progressing when checks are incomplete, and lodge reports with AUSTRAC when needed.

Hard deadline

Your business must enrol with AUSTRAC by 29 July 2026 if you are newly regulated and already providing designated services from 1 July 2026. If your agency starts providing a designated service after 1 July 2026, you must enrol within 28 days of first providing it. The compliance officer should be chosen before enrolment so AUSTRAC contact details, internal responsibility and implementation are clear from day one.

What the principal of a real estate agency should do now

  • Choose one responsible person to lead AML/CTF compliance across your property sales business, preferably someone with authority over agents, admin staff and trust-account related processes.
  • Define the role in writing: AUSTRAC enrolment, overseeing the ML/TF risk assessment, finalising the AML/CTF program by 31 December 2026, monitoring CDD and sanctions screening, and making sure suspicious matter reports are lodged on time.
  • Set up practical controls for your office: when buyer and seller ID must be verified, who screens names against DFAT and UN sanctions lists, who reviews unusual source-of-funds explanations, and how records are stored for 7 years.
  • Train frontline sales staff and support staff so they know when to escalate red flags, such as a buyer refusing to meet, using opaque company structures, relying on unexplained third-party funds, or wanting to buy high-value property without inspection.
  • Make sure the compliance officer can stop shortcuts. A listing urgency, auction timetable or pressure from a developer must not override identity checks, sanctions screening or reporting duties.

A common mistake in real estate is assuming the sales agent handling the listing can just 'keep an eye on it' informally. AUSTRAC expects a real business process, not a vague understanding. Another mistake is treating this as only a trust-account issue. Your risk starts earlier, including buyer onboarding, seller instructions, offshore connections, nominee arrangements, rapid resales, unusual deposit patterns and purchases through companies or trusts where the real controller is not obvious. The compliance officer should also know that AML/CTF obligations are federal and apply across Australia, regardless of the state licensing regime.

For a suburban agency, practical setup matters more than bureaucracy. Use one central register for customer identification, beneficial owner checks for company and trust buyers, sanctions screening results, staff training records and escalations. Build AML checkpoints into your sales workflow: at listing, before accepting offers, before exchange and before handling any physical cash. Remember that a threshold transaction report only applies to physical currency of $10,000 or more, not card payments or EFTs. The compliance officer should also be the person staff call before anyone says anything to a client about a possible suspicious matter report, because tipping off is a separate criminal offence.

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Frequently asked questions

Does AUSTRAC require me to hire a separate compliance officer for my agency?
No. For a small real estate business, the role can be done by the principal, director or another senior person with enough authority to enforce the rules. The key issue is not job title but whether that person can control onboarding, reporting, training and escalation.
I only run a small residential agency with a few sales staff. Do I still need to appoint someone?
Yes, if your business provides a designated service. Small agencies are not exempt from having someone take responsibility for compliance. AUSTRAC is bringing sole traders and small practices into the regime as well as larger groups.
Can my office manager handle this instead of the licensed principal?
Yes, if your office manager has the seniority, access and authority to make staff follow the process and escalate issues. In many agencies the principal still keeps oversight, even if the office manager runs the day-to-day administration. The role should be documented clearly so there is no confusion about responsibility.
What will it cost to appoint a compliance officer?
AUSTRAC enrolment itself is free. Your cost is internal time, staff training, setting up screening and recordkeeping processes, and getting your AML/CTF program in place by 31 December 2026. For many small agencies, the cheapest option is assigning the role internally and using AUSTRAC guidance and sector starter materials.
What if I sell property through a company trust account arrangement or for an overseas buyer?
Those deals usually need closer attention, not less. The compliance officer should make sure the agency verifies the customer properly, identifies beneficial owners for companies and trusts, screens all relevant parties against sanctions lists, and considers whether enhanced due diligence is needed because of ownership complexity, high-risk countries or unusual funding.

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