AML/CTF Business Risk Assessment Template – Real Estate Agencies (Australia)
For newly regulated Tranche 2 reporting entities
$750.00 +GST
Free Download for COMPASS Members
- Assess 39 ML/TF risk factors across customers, channels and jurisdictions;
- Score each risk using a three-by-three likelihood and impact matrix;
- Apply jurisdiction risk ratings across 214 countries from five data sources;
- Record AUSTRAC feedback, review dates and approvals in built-in registers.
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About this Document
This Business Risk Assessment template gives Australian real estate agencies a worked ML/TF risk assessment covering the brokering service that brings them within the AML/CTF Act. It is built for agencies newly captured by the Tranche 2 reforms and draws on AUSTRAC's real estate program starter kit.
Use this template if you:
- Broker the sale, purchase or transfer of real estate in Australia
- Have been newly captured as a reporting entity under the Tranche 2 reforms
- Need a documented business risk assessment before providing designated services
- Want a worked starting point rather than an empty risk register
- Review and re-rate your risks at least every 12 months
It is suited to:
- Real estate agencies providing the brokering service under table 5 of the AML/CTF Act
- AML/CTF Compliance Officers preparing a first business risk assessment
- Principals and directors carrying governing body oversight of AML/CTF compliance
- Agencies that are not part of a reporting group and do not provide a registrable remittance or virtual asset service
What this template covers:
- 35 worked risk factors on the general tab, each with likelihood, impact, risk score and control measures already completed
- Four real estate risk factors: unfinanced transactions of $1.5 million or more, physical currency of $50,000 or more, virtual asset payments and unusual service requests
- Customer profile risks across individuals, non-individual structures, third parties acting under authority, PEPs and sanctions matches
- Delivery channel risks across face-to-face dealings, remote onboarding, third-party arrangements and accepted payment methods
- Jurisdiction risk, supported by a rating tool covering 214 countries built from the Basel AML Index, FATF classifications, prescribed foreign countries, DFAT sanctions and the EU high-risk list
- Internal practice risks across AUSTRAC enrolment, CDD failures, suspicious matter and threshold transaction reporting, tipping off, data breaches, personnel training and screening
- A proliferation financing assessment covering jurisdictions and persons of proliferation concern and targeted financial sanctions obligations
- A version control register and an AUSTRAC risk products and feedback register
You receive an editable multi-tab spreadsheet with worked example risk factors, likelihood and impact commentary, and control measures cross-referenced to your AML/CTF Policy, plus fields marked for you to complete. The examples are drawn from AUSTRAC guidance and are not exhaustive, so review and tailor each risk factor to your agency; complex or higher-risk arrangements may still warrant tailored legal advice.
How To Use This Template
This template is a starting point, not a final document. It’s been drafted by Australian lawyers to be practical and flexible, but it still needs to be reviewed and tailored for your specific business, transaction and risk profile.
Before you use it, you should:
- Complete all placeholders, bracketed items and optional fields;
- Remove any drafting notes or clauses that aren’t relevant to your situation; and
- Check that party names, entity details, dates, addresses, contact details and defined terms are accurate.
Make sure the template is consistent with your other documents and obligations – including any existing contracts, policies, procedures, website terms, privacy disclosures, regulatory requirements or internal governance documents. If anything conflicts, it should be resolved before you sign, issue, adopt or implement the document.
If you are using the template as an agreement, it should be reviewed and signed by all relevant parties in accordance with applicable law and your internal signing requirements. If you are using it as a policy, procedure, notice or compliance record, it should be approved and stored under your organisation’s normal document control processes.
This template is provided as general information only and is not legal advice. Complex, high‑value, highly regulated or cross‑border matters will usually require bespoke drafting. For anything outside a straightforward use case, we strongly recommend obtaining legal advice before relying on, signing or implementing this document.
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