If your agency provides a designated service under the Tranche 2 reforms, you must train the people in your business who deal with buyers, sellers, landlords, investors, funds, onboarding or transaction activity so they can follow your AML/CTF program in day-to-day real estate work. For real estate businesses, training is not a box-ticking exercise: it is how your sales, property management and support staff learn when to identify customers, spot red flags, escalate concerns and avoid tipping off. If you do not comply, AUSTRAC can take enforcement action, civil penalties can reach $33.5 million per contravention, and intentional breaches can also carry criminal penalties.
Your AML/CTF obligations
For a real estate agency, staff training must be built around the actual jobs people do. Your training needs to cover your AML/CTF policies, the ML/TF risks in your business, and each person’s responsibilities under the program. That means front-desk staff who collect ID, sales agents handling buyer and seller interactions, staff involved in deposits or trust-related processes, and anyone reviewing unusual activity need different training depth. AUSTRAC expects training to be accessible and understandable for the person receiving it, so one generic online module for everyone is not enough on its own.
What a real estate agency should do in practice
AUSTRAC’s expected training frequency
AUSTRAC guidance says AML/CTF compliance officers and senior management should be trained every 6–12 months. Customer-facing personnel, and personnel responsible for onboarding, transaction monitoring or other enhanced CDD roles, should be trained every 12 months. Third-party vendors should be trained when onboarded and when the contract is renewed or changed. Personnel not in AML/CTF-relevant roles should receive general awareness training at onboarding.
For real estate, the most useful training is scenario-based. Use examples your team will actually see: a buyer using a shelf company with a vague controller, a purchaser insisting on urgency while resisting ID checks, a family member paying part of a deposit without a clear reason, a sanctioned name match, or a client trying to split physical cash to avoid the $10,000 threshold. Staff need to know that physical cash of $10,000 AUD or more can trigger a threshold transaction report within 10 business days, that suspicious matter reports must be lodged within 3 business days of forming a suspicion or within 24 hours for terrorism financing, and that telling the client about an SMR is a criminal offence.
Common mistakes in real estate agencies
A practical approach for a small agency is to build short role-based modules: one for principals and senior managers, one for sales and buyer’s agents, one for onboarding and admin staff, and one for trust or payments staff where relevant. Use AUSTRAC’s e-learning as a supporting tool, then add your own process steps, escalation contacts, scripts for asking clients for documents, and examples from your market. Keep attendance logs, copies of materials, quiz results and version control with your AML/CTF program documents, and retain those records for 7 years after the relationship ends.
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