AML/CTF Policy Template – Real Estate Agencies (Tranche 2 | Australia)

This AML/CTF policy is purpose-built for Australian real estate agencies brought into the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) by the tranche 2 reforms, with obligations commencing on 1 July 2026. It sets out how your agency identifies, mitigates and manages money laundering, terrorism financing and proliferation financing risk arising from the brokering service you provide, and draws on AUSTRAC's real estate program starter kit throughout.

Use this policy if you:

• Broker the sale, purchase or transfer of real estate on behalf of a customer
• Provide that service at or through a permanent establishment in Australia
• Are enrolling with AUSTRAC, or have enrolled, as a tranche 2 reporting entity
• Need the governance, CDD and reporting framework that sits alongside your Business Risk Assessment
• Are appointing an AML/CTF compliance officer and documenting how the role operates

It is suited to:

• Residential, commercial and rural agencies
• Sole trader agents and single employee businesses
• Franchise offices and agencies within a reporting group
• Principals, directors and newly appointed AML/CTF compliance officers

What this policy covers:

• Your brokering service under table 5 of the AML/CTF Act, the geographical link test and AUSTRAC enrolment timing
• Governing body duties, the AML/CTF compliance officer role, senior managers and single employee arrangements
• Risk factors across the brokering service, customers, delivery channels and countries, with Basel AML Index, FATF and DFAT country risk settings
• Initial CDD on both the direct customer and the counterparty, including delayed CDD and counterparty non-cooperation
• Beneficial ownership, politically exposed persons, sanctions screening, enhanced CDD, and source of funds and wealth
• ML/TF methods relevant to real estate — trust account misuse, shell and offshore companies, over and undervaluation, quick resale and the use of non-financial professionals
• SMRs, TTRs, cross-border movement reports, the annual compliance report due 31 March and the tipping off prohibition
• Record retention periods, personnel due diligence, training, effectiveness checks, independent evaluation, reporting groups and proliferation financing

You receive an editable Word document running to eleven sections, with a definitions table linking to the AML/CTF Act, the AML/CTF Rules and AUSTRAC guidance. Bracketed fields such as [Client Name] and [Insert date] mark what you complete, and the illustrative examples and non-exhaustive risk factors are there to be tailored or deleted before your governing body adopts the policy. It is scoped to the table 5 brokering service rather than the table 6 professional services, is designed to be read with your Business Risk Assessment and onboarding documents, and should be reviewed by a suitably qualified AML/CTF adviser for your circumstances before adoption.