AML Compliance Guide

Staff training for Real estate agents — 2026 AUSTRAC Guide

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.

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

  • Map who needs training: licensee or owner, sales agents, buyer’s agents, property staff, reception, onboarding staff, finance or trust account staff, and contractors or third-party providers involved in customer-facing or AML/CTF-relevant work.
  • Match the training to the role: customer-facing staff should know when to collect and verify ID, when to stop a matter until checks are complete, how to recognise PEPs, sanctions hits, nominee buyers, unexplained source of funds, rushed cash-heavy deals and unusual ownership structures.
  • Set a training schedule and keep records: document who was trained, when, what topics were covered, how it was delivered and any assessment or sign-off. Repeat training when your AML/CTF program changes.

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

  • Assuming only salespeople need training. Reception, trust-related staff, compliance support staff and business owners also need training if they touch onboarding, customer information or transaction activity.
  • Relying entirely on a generic external course. You can outsource delivery, but you still must tailor it to your agency, your services, your risk assessment and your procedures.
  • Waiting until a problem arises. Training should be refreshed as soon as practicable after changes to AML/CTF laws, new risks, program updates, compliance review findings or a breach.

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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Frequently asked questions

Do all staff in my agency need AML/CTF training, or only sales agents?
Not only sales agents. Anyone who deals with customers, collects identification, handles onboarding, reviews transaction activity, manages relevant payments processes, or supervises those functions should receive training suited to their role. Staff with no AML/CTF-relevant role still need general awareness training at onboarding.
Can I just buy an online compliance course and use that for everyone?
Not by itself. AUSTRAC says its own e-learning modules, and outsourced training generally, cannot be relied on solely because training must be tailored to the person’s AML/CTF functions, the risks relevant to that function, and their responsibilities under your policies. A generic course can be part of your approach, but you need to adapt it to your agency’s real estate processes.
What if I use contractors, virtual assistants or an external onboarding provider?
If they perform AML/CTF-relevant work for your business, they need training appropriate to that work. AUSTRAC guidance expects third-party vendors to be trained when they are onboarded and when the contract is renewed or changed. You remain responsible for making sure outsourced training is suitable and aligned with your AML/CTF program.
How much will this cost a small real estate agency?
The law does not set a minimum spend. A small agency can keep costs down by using a mix of short internal sessions, AUSTRAC resources, simple role-based checklists and targeted external training for higher-risk roles such as principals or staff handling enhanced due diligence. The key is not cost; it is whether the training is documented, understandable and matched to your actual risk and procedures.
What records do I need to keep to prove staff training happened?
Keep a training register showing who was trained, their role, the date, delivery method, topics covered and any assessment or acknowledgement. Also keep copies of the materials used, attendance records, updates made after law or program changes, and any vendor training records. Training records should be kept with your AML/CTF documentation and retained for 7 years after the relationship ends.