AML CTF compliance for Australian real estate agents
From 1 July 2026, you're an AUSTRAC reporting entity. Enrolment opens 31 March and closes 29 July 2026. We turn AUSTRAC's real estate starter kit into 4 working AI workflows in 14 days. Fixed at $4,500.
Are you a Tranche 2 real estate entity?
Four yes/no questions. If you answer yes to any of them, you're likely in scope from 1 July 2026.
Tranche 2 brings the real estate sector under AUSTRAC
REIA represents 85% of Australian real estate businesses. Most agencies have a peak-body partnership with First AML — a fully featured platform built for top-200 networks. Smaller agencies need implementation, not another platform fee.
REIA + First AML — the partnership we sit alongside, not against
REIA (national), REIV and REISA have publicly endorsed First AML as a preferred AML/CTF technology partner; other state institutes are running educational programs in collaboration with First AML. It's a strong end-to-end platform — and the right call for top-200 networks like Raine & Horne and LJ Hooker, where multi-office workflows and PEXA/MRI integrations earn the platform fee.
Where we fit: agencies under 15 staff, single office, mid-volume sales — where a SaaS platform is over-engineered and the AUSTRAC starter kit is under-implemented. We turn the kit into operating workflows in 14 days. If you later add First AML, our workflows sit on top.
The 5 AUSTRAC obligations through a real estate lens
Every Tranche 2 entity has the same five obligations under the AML/CTF Act 2006 (amended 2024). Here's what each means for an agency providing designated services.
Enrol with AUSTRAC
If your business brokers the purchase, sale or transfer of real estate, you provide a designated service. Enrolment opens 31 March 2026 and closes 29 July 2026 — 28 days after obligations commence on 1 July. Enrolment is free and done online via AUSTRAC.
AML/CTF program
You need a written, board-approved program covering risk assessment, controls, training, governance, and an appointed AML/CTF Compliance Officer. AUSTRAC's free real estate starter kit is the foundation — it must be customised to your services, customer base and risk exposure.
Customer due diligence (CDD)
Verify identity for buyers and vendors, map beneficial ownership for corporate or trust purchasers, and check source of funds for cash deposits. The AML/CTF Rules 2025 (tabled in Parliament August 2025) allow delayed CDD on buyers and reliance on conveyancer due diligence in some scenarios.
Suspicious matter reports (SMR)
If you form a reasonable suspicion of money laundering — structured cash deposits, dummy bidding patterns, third-party payers, unusual settlement instructions — you must lodge a SMR with AUSTRAC within strict timeframes. Tipping off the customer is a separate offence with up to 5 years imprisonment.
Records retention
Keep CDD records, transaction records, training logs, risk assessments, program documentation and decisions about SMRs for 7 years after the end of the customer relationship. Records must be retrievable for AUSTRAC examination under s.172A powers.
Real estate AML risk scenarios
Three patterns AUSTRAC has flagged as high-risk in property. The AI flags the trigger; the principal makes the legal judgement.
Structured cash deposits
Buyer pays the 10% deposit across multiple transactions each just under $10,000 — bank transfers from different accounts, mixed with cash to the trust account.
Multiple deposits to the same matter under reporting thresholds within a short window; mismatched payer names; inconsistent source-of-funds story.
Whether the pattern reaches "reasonable grounds to suspect" — the principal's judgement, supported by the program's escalation steps.
Opaque corporate purchaser
Foreign company purchases an investment property. The director on file is a nominee; the beneficial owner sits behind a layered offshore trust structure with no clear UBO.
Beneficial ownership chain that cannot be traced to a natural person; PEP hits; jurisdiction risk; mismatch between purchaser entity and source-of-funds documentation.
Whether to apply enhanced CDD, decline the transaction, or proceed with an SMR. Legal review of beneficial ownership rules is yours, not the AI's.
Third-party settlement payer
Vendor instructs that settlement funds be paid to a third party not on the title — a relative, a company, or an offshore account. Reasoning provided is vague.
Payment direction mismatch with title holder; third-party jurisdiction risk; instruction received late in the matter; documentation gaps.
Whether to seek further documentation, escalate to compliance counsel, or report. The AI drafts the SMR; the principal verifies and submits.
The 4 AI workflows, rewritten for real estate
Each workflow connects to your existing systems — Property Tree, Box+Dice, MRI Software, VaultRE, AgentBox. Built on the AUSTRAC starter kit. You keep the IP.
1 · CDD Intake Agent
Smart onboarding for buyers and vendors — handles ID verification, beneficial ownership for corporate purchasers, and source-of-funds prompts for unusual deposits.
- Buyer/vendor onboarding form with VOI prompts
- Beneficial ownership mapping for corporate or trust purchasers
- Source-of-funds questions for cash deposits over threshold
- PEP and sanctions list screening on every match
2 · Training Register Automation
Tiered training register — sales agents, property managers, trust account handlers, and the principal each get the right module on the right cadence.
- Auto-renewal reminders before training expires
- Role-based completion tracking with attestations
- AUSTRAC-ready export of training evidence
- 7-year retention with audit-ready timestamps
3 · SMR Draft Assist
Pre-built templates for the patterns AUSTRAC flags in real estate. Drafts in AUSTRAC format from your file notes. The principal reviews and submits — the AI never submits.
- Templates for structured cash, third-party payers, dummy bidding
- Pulls relevant facts from matter notes and CDD records
- Drafts in the AUSTRAC SMR format ready for sign-off
- Auto-records the decision rationale for the file
4 · Ongoing Monitoring & Alerts
Light-touch transaction monitoring on trust account flows, beneficial ownership change checks, and quarterly review reminders so nothing slips between settlements.
- Unusual trust account pattern alerts
- Beneficial ownership change checks for property managers
- Quarterly program review reminders
- Annual risk assessment refresh prompts
Built and delivered by Joel — direct, not outsourced
Square AI is a Penrith-based AI implementation studio. The Sprint is delivered personally — no account managers, no offshored build team, no junior consultants learning on your dollar. I read AUSTRAC guidance daily, I've built every workflow that ships, and I sit on the readiness call you book.
Trade-off: I run 4–6 Sprints per month, not 40. Founder pricing is locked for the first 100 firms. After that, the price moves to standard rates.
See how the workflows actually run
Walk through the AI agents the way your sales staff and principal would — onboarding a corporate buyer, logging staff training, drafting an SMR from file notes after a structured-cash trigger, and triggering a beneficial ownership refresh. No signup. No sales call. Roughly 5 minutes end to end.
Watch the live demoPricing — no platform fees, no lock-in
A fixed-price sprint to get you live, plus an optional retainer if you want us to keep watch after go-live. Compatible with First AML, AMLHUB, or stand-alone.
AML/CTF AI Sprint
- Customised AML/CTF program from AUSTRAC's real estate starter kit
- 4 AI workflows: CDD Intake, Training Register, SMR Draft Assist, Monitoring
- Integration with your CRM and trust account software
- 1 × 60-minute live staff training session
- Audit-ready evidence pack: policies, registers, training logs
- You own the IP — no platform lock-in
Optional Monthly Retainer
- Quarterly program reviews and updates
- Training register monitoring and renewals
- Workflow tweaks as your business changes
- Email support during business hours
- Compatible with First AML, AMLHUB or stand-alone
From kick-off to live program in 14 days
No surprises. Each week has a single deliverable. The principal signs off the program before staff training.
Week 1
Discovery + program customisation
We review your services, transaction flows, customer base and existing controls against the AUSTRAC real estate starter kit. We map gaps and customise risk assessment, policies and processes to your agency.
Week 2
AI workflow deployment + integrations
The four workflows go live and connect to your CRM (Property Tree, Box+Dice, MRI Software, VaultRE, AgentBox), trust account software, and team calendar. Workflows are tested with real matter scenarios.
Day 14
60-min staff training + program live
Live training session for sales staff, property managers and the principal. Training register goes live the same day. You leave with an audit-ready evidence pack and a working AML/CTF program.
Why us for real estate agencies under 15 staff
There are four ways through the deadline. Pick the right one for your size.
Option 1
DIY starter kit
- Free from AUSTRAC
- 80+ partner hours to customise
- No AI workflows — manual registers
- You own everything, you build everything
- Right for: 1–3 staff with time and confidence
Option 2
First AML platform
- Best-in-class enterprise platform
- Per-seat or per-check pricing
- End-to-end CDD, monitoring, audit
- REIA + most state REIs endorsed
- Right for: top-200 networks, 50+ staff
Option 3
SaaS platform alone
- $59–$759/mo, ongoing forever
- InfoTrack (free + per-search), AML Assured, AMLTranche, AMLHUB
- Software, not an implemented program
- You customise the starter kit yourself
- Right for: agencies with internal compliance time
Option 4 — us
Square AI Sprint
- $4,500 fixed, 14-day delivery
- 4 AI workflows on top of the AUSTRAC kit
- AUSTRAC-aligned, not AUSTRAC-approved
- You keep the IP, no lock-in
- Right for: agencies under 15 staff
AUSTRAC publishes free starter kits. We turn them into running AI workflows.
The real estate program starter kit on austrac.gov.au is a complete framework — risk assessment, policies, processes, forms. The gap is implementation. We bridge that gap in 14 days. You keep the IP. No platform lock-in.
View AUSTRAC's real estate starter kit →Frequently asked questions
AUSTRAC enrolment opens 31 March 2026 and closes 29 July 2026 — 28 days after Tranche 2 obligations commence on 1 July 2026. Providing a designated service after 1 July without being enrolled is a contravention of s.51B of the Act. Practical advice: enrol in April or May 2026, not late July. The Sprint timeline is built around being enrolled, programmed and operational well before 1 July.
Property managers themselves usually aren't providing a designated service when they collect rent or manage tenancies. But if your agency also handles sales, off-the-plan transfers, or trust account funds tied to property purchases, anyone with visibility of those flows needs role-appropriate training. The safest position: train all staff with any line of sight to a sales transaction — and document who got what.
Buyer's agents are explicitly captured. AUSTRAC names "acting on behalf of buyers or sellers to arrange the sale, purchase, or transfer of property" as a designated service. From 1 July 2026, you must enrol with AUSTRAC, have a customised program, and conduct CDD on your buyer client and on the vendor side where you're handling funds.
No. AUSTRAC doesn't endorse or require any specific platform. First AML is a strong fit for top-200 networks but is not a compliance requirement. AUSTRAC's own real estate starter kit is free and sufficient if it's properly customised and operationalised. We turn it into 4 working AI workflows for $4,500. You can always add First AML later if you scale.
Yes. Our workflows sit on top of your existing CRM and trust account software. We've designed them to slot in alongside Property Tree, Box+Dice, MRI Software (VaultRE, Eagle), AgentBox and most other Australian real estate stacks. We don't replace your PMS — we connect to it so CDD records, training logs and SMR drafts stay where you already work.
The AI flags the pattern, drafts the report in AUSTRAC's SMR format, and routes it to the principal or AML/CTF Compliance Officer for review. The principal reviews, edits and personally submits — the AI never submits. The decision rationale is logged to the file automatically, which helps if AUSTRAC later examines the matter under s.172A powers.
The program must be approved by the governing body or senior management — for most independent agencies, that's the principal or licensee in charge. You also appoint an AML/CTF Compliance Officer with delegated responsibility for compliance oversight. Sole-practitioner agencies wear both hats. We help you scope the appointment and document the delegation as part of the Sprint.
AUSTRAC defines designated services for real estate as: acting on behalf of a buyer or seller to arrange a property sale, purchase or transfer; selling or transferring property directly without an independent agent; and providing auctioneer services unless the auctioneer is the seller's agent on the same sale. Property management on its own is not a designated service. Trust account work tied to a sale is.
The civil penalty regime applies equally — up to $33 million corporate or $6.6 million individual per contravention, calculated at the current penalty unit value of $330 (set under s.4AA Crimes Act 1914 and indexed every three years from 1 July 2026). Money laundering offences under Criminal Code s.400 carry up to 25 years imprisonment. Tipping-off (s.123) carries up to 5 years. AUSTRAC has signalled an education-first stance for newly regulated entities through 2026, but enforcement powers are live from 1 July.
15-minute real estate readiness call
Tell us about your agency. We'll tell you what's in scope, what's not, and whether the Sprint is right for you. No pitch deck, no obligation.
Same Sprint, different sector context — built on the matching AUSTRAC starter kit:
Don't be the agency that missed the deadline.
14 days to a working AML/CTF program. $4,500 fixed. AUSTRAC-aligned, not AUSTRAC-approved. We implement — we don't advise.