AUSTRAC is currently finalising the AML/CTF rules for real estate agents, with the final version expected to be published

in Q3 2025. In the meantime, we’ve summarised what AUSTRAC is currently indicating the rules will cover, based on their latest consultations and guidance. This page will be regularly updated as new information is released, so be sure to check back for the latest details once the final rules are published.

 

Key Obligations Summary

Businesses regulated by AUSTRAC must:

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• Enrol and register with AUSTRAC

• Develop and maintain an AML/CTF program tailored to their business

• Conduct initial and ongoing customer due diligence (CDD)

• Report certain transactions and suspicious activities

• Make and keep accurate records

 

Meeting AML/CTF obligations is essential to protect your business from criminal misuse and to comply with Australia’s AML/CTF laws. 

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1. Enrol and Register with AUSTRAC
If you provide one of the newly regulated services, you must enrol with AUSTRAC. Virtual asset service providers (VASPs) offering these services must also apply for AUSTRAC registration.  Enrolment involves providing information about your business structure, services, key personnel and contact details. Updates are required when information changes.

You must enrol within 28 days of providing a designated service to avoid penalties.

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2. Develop and Maintain an AML/CTF Program
Your AML/CTF program protects your business from money laundering, terrorism financing and proliferation financing. It must include:

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• A risk assessment of ML/TF/PF threats relevant to your business.

• Policies and controls to manage risks and ensure compliance.

• Documentation approved by senior management and updated regularly.

• Independent evaluation at least once every 3 years.

• Oversight by senior management and an appointed AML/CTF Compliance Officer.

• Businesses may also form reporting groups to share compliance costs, pending finalisation of AUSTRAC’s AML/CTF Rules.

 

3. Conduct Customer Due Diligence (CDD)

• CDD ensures you understand your customers and their ML/TF/PF risks. It includes:

• Initial CDD: Verifying customer identity before providing services.

• Ongoing CDD: Monitoring transactions, updating risk profiles, and re-verifying information when necessary.

• Enhanced CDD (ECDD): Applied in higher-risk scenarios.

• Simplified CDD: For lower-risk customers.

• Pre-commencement customers require CDD only when filing a Suspicious Matter Report (SMR) or when their risk level increases due to changes in the relationship.

 

4. Report Transactions and Suspicious Activity
AUSTRAC requires specific reports, including:

• Suspicious Matter Reports (SMRs): For suspected identity fraud, criminal activity, or proceeds of crime.

• Threshold Transaction Reports (TTRs): For cash transactions of A$10,000 or more.

• International Value Transfer Service Reports (IVTS).

• Cross-Border Movement Reports: For physical currency or bearer negotiable instruments of A$10,000+ entering or leaving Australia.

• Annual Compliance Reports: Summarising compliance performance.

 

5. Make and Keep Records
You must keep accurate, complete records for 7 years, including:

• AML/CTF program documentation

• CDD records

• Transaction records

• Staff training logs

• Audit reports

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If you'd like more information on any of the above, or would like to discuss AML advisory, technology, AML staff training or outsourcing KYC and more, please contact us using the Live Chat on the home page, or contact us using the details in the header and footer of this website.