AML/CTF compliance for real estate.
Property transactions are among the highest-risk channels for money laundering in Australia. From 1 July 2026, real estate agents must comply with the AML/CTF Act, including client screening, transaction monitoring, and suspicious matter reporting.
- Cash payments for property deposits or settlements
- Use of third parties to obscure the true buyer or seller
- Purchases through complex corporate or trust structures
- Properties bought significantly above market value
- Rapid buying and selling of properties (flipping) without renovation
- Foreign buyers using nominees or shell companies
- Reluctance to provide identification or source of funds information
- Transactions involving countries identified as high-risk by FATF
The Challenge for Real Estate
The Australian real estate sector processes hundreds of billions of dollars in property transactions each year. AUSTRAC and the FATF have identified property as a primary vehicle for laundering the proceeds of crime — from drug trafficking to fraud and corruption.
Under Tranche 2, real estate agents will face the same types of obligations that banks and financial institutions have managed for years. This means new processes, new documentation requirements, and new reporting responsibilities.
The challenge is significant: most agencies have no existing AML/CTF infrastructure. Agents need to build compliance programs from scratch, train their teams, and implement systems that can handle client due diligence, screening, and reporting — all without disrupting their core business.
The good news: with the right tools, compliance doesn't have to be expensive or time-consuming. Clear Check is purpose-built for exactly this transition.
Your Obligations as a Real Estate Agent
Under the AML/CTF Act, real estate agents providing designated services must meet these four core obligations.
Client Identification & Verification
- Verify the identity of all buyers and sellers before settlement
- Identify beneficial owners of corporate or trust purchasers
- Apply enhanced due diligence for foreign buyers and complex structures
- Collect and verify government-issued identification documents
- Screen all parties against DFAT sanctions lists and PEP databases
Transaction Monitoring
- Monitor property settlements for unusual patterns
- Flag trust account transactions exceeding $10,000 in cash
- Report threshold transactions (cash payments of $10,000 or more)
- Watch for structuring: multiple transactions designed to avoid reporting
- Monitor for properties purchased significantly above or below market value
Record Keeping
- Retain all CDD records for a minimum of 7 years
- Maintain audit-ready documentation for every transaction
- Keep copies of all identification documents collected
- Document your risk assessments for each client relationship
- Store all screening results with timestamps and outcomes
Suspicious Matter Reporting
- Submit SMRs to AUSTRAC within 24 hours for terrorism-related matters
- Submit SMRs within 3 business days for all other suspicious matters
- Report threshold transactions (cash of $10,000+) within 10 business days
- Never disclose (tip off) that an SMR has been or will be filed
- Maintain internal records of all reports submitted to AUSTRAC
How Clear Check Helps Real Estate Agents
Every feature maps to a specific obligation. No unnecessary complexity — just the tools you need to be compliant.
Sanctions & PEP Screening
Screen buyers, sellers, and beneficial owners against DFAT sanctions, PEP databases, and global watchlists in seconds. Results include a compliance-ready audit trail.
Covers obligation
Client identification
Risk Assessment Builder
Generate a sector-specific risk assessment for your real estate practice. Guided workflows cover property types, client profiles, geographic risk, and transaction patterns.
Covers obligation
AML/CTF program
AML/CTF Program Builder
Create a compliant AML/CTF program with Part A (risk-based systems and controls) and Part B (KYC procedures) tailored to property transactions.
Covers obligation
Program development
Automatic Audit Trail
Every check generates a timestamped, tamper-evident record. Export PDF reports for AUSTRAC inspections. 7-year retention built in.
Covers obligation
Record keeping
Training Modules
Online AML/CTF training modules designed for real estate teams. Track completion, issue certificates, and demonstrate staff competency to auditors.
Covers obligation
Staff compliance
Get compliant before July 2026
Full AML/CTF screening and compliance tools from $49/month
No per-check fees on subscription plans. Australian hosted. No lock-in contracts.