Starting 1 July 2026, Australian real estate agents will be required to comply with stringent AML/CTF1 regulations, including enrolling with AUSTRAC, implementing a tailored compliance program, conducting thorough customer due diligence, and reporting suspicious activities. These measures aim to align the real estate sector with international standards and enhance the integrity of Australia’s financial system.
RAC Pro can assist by providing technology-based compliance services across the Real Estate Sector, particularly for Real Estate Agencies with multiple franchises or owned agencies.
The Challenges
Real estate agents will face several challenges in implementing an AML/CTF program starting in 2026. These include:
- Centralised Leadership: The absence of a designated AML/CTF compliance management at a senior level can lead to a lack of accountability and transparency within the agencies.
- Training Deficiencies: There is often a gap in training for agency staff, which can result in inadequate processes and compliance readiness;
- Inadequate Documentation: Many agencies lack a formal, documented AML/CTF program tailored to their specific risks, leading to process breakdowns;
- Outdated Systems: Agencies continue to use outdated and manual compliance methods like spreadsheets and paper files, which are inefficient and prone to human error;
- Lack of Technology: There is a lack of effective technology or IT solutions to automate and streamline key AML/CTF functions.
The Consequences of not preparing
These challenges highlight the need for real estate agents, as reporting entities, to prepare adequately to ensure they meet Austracs’ 7-point expectations for Tranche 2 compliance by July 1, 2026. These are:
- Be enrolled as a reporting entity (enrolment opens 31 March 2026)
- Have an AML/CTF program
- Have an AML/CTF compliance officer
- Having trained Staff in the program and internal processes
- Be ready to engage with clients and report suspicious matters
After July 1, 2026:
- Do not wilfully ignore the obligation to enrol, and
- Do not be complicit with or wilfully ignore money laundering activities
RAC Pro and the Solutions
The solution for Real Estate agents can be found by understanding the step-by-step process in conducting an AML/CTF program:
- Conduct a risk assessment
- Appoint an AML/CTF compliance officer
- Establish customer due diligence (“CDD”) policies
- Conduct employee training
- Establish transaction reporting
- Demonstrate recording keeping and reporting
- Conduct independent reviews
The challenges in implementing these steps can, in part, be addressed by using RAC Pro. Let’s look at these steps:
- Your AML/CTF program must take a risk-based approach.
RAC Pro’s “Risk” module provides a risk analysis program for your business. The identified inherent and residual risks, along with the controls that mitigate each, can be presented in platform-generated reports as heat maps. - Each reporting entity must appoint an AML/CTF Compliance Officer.
You can create “Role and Contact Checklists” in RAC Pro. Team Members can be assigned a role, eg. AML/CTF Compliance Officer, with a checklist of questions and attachments relating to the role. - Before providing services, businesses must verify customer identities and assess their risk profile.
“Entity Onboarding” and “Team Member Roles and Contact Checklists” can be used to record specific information in RAC Pro. Attachments can be marked as sensitive, meaning they can only be viewed by the relevant Team Member and their Supervisors. - Regular AML/CTF training ensures staff can identify, assess and report suspicious matters.
RAC Pro’s “Training” module can set AML/CTF training for your employees. Completed training will automatically transfer to the “Training Register”, which can be reported on at any time. - Transaction monitoring helps detect unusual transactions and behaviours.
Transaction monitoring procedures could be added to the “Policy Library” in RAC Pro, with acceptance recorded at both the entity and user level. RAC Pro also includes a range of “Registers” for your compliance needs, with the flexibility to add registers as required for incident reporting. - Businesses must report certain transactions to AUSTRAC.
The RAC Pro “Registers” module is used to record and manage registers, such as training, complaints, and breaches, to demonstrate accountability actively. You can filter information and report on your registers at any time. Reports can be produced in both PDF and CSV formats. - Your AML/CTF program must be independently reviewed at least every three years.
The RAC Pro “Policy Library” module enables you to develop, manage and deploy policies and procedures that can be shared down through to agencies. You can set Review dates and Review frequency for all of your policies so they are flagged for review.
(1) AML/CTF – Anti-money laundering and counter terrorism financing