AML/CTF Process Document and Forms Template – Real Estate Agencies (Australia)

For real estate agencies under tranche 2

$499.00 +GST

Use this template to:
  • Record AML/CTF role holders, assigned responsibilities and personnel due diligence;
  • Complete initial and enhanced CDD, PEP and sanctions checks;
  • Escalate unusual activity and record suspicious matter report decisions;
  • Report annually to your governing body and log AUSTRAC enrolment.

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Personnel forms for AML/CTF roles and responsibilities

About this Document

This Process Document and Forms template contains the complete set of working forms referenced throughout the Click Legal AML/CTF Policy (Real Estate). It holds 27 numbered forms across four parts, each cross-referenced to the Policy clause it supports, and is designed to be read together with that Policy and your business risk assessment.

Use this template if you:

  • Are a real estate agency providing a brokering service under the tranche 2 reforms
  • Have an AML/CTF policy in place and need the forms that sit underneath it
  • Need a consistent written record of every due diligence, escalation and reporting decision
  • Want form fields you can rebuild inside your existing CRM or case management system
  • Run a single employee business and need the conflict of interest variants

It is suited to:

  • Real estate agencies of any size, including single employee businesses
  • AML/CTF compliance officers who assess escalations and suspicious matter reports
  • Customer-facing staff who complete onboarding, verification and review forms
  • Directors and senior managers who approve appointments, enhanced due diligence and action plans
  • Agencies preparing for an independent evaluation of their AML/CTF policy

What this template covers:

  • Personnel forms: roles, assigned responsibilities, due diligence and a statutory declaration checklist (Forms 1 to 6)
  • Onboarding and initial CDD, including beneficial ownership mapping, PEP checks and DFAT sanctions checks (Forms 7 to 8)
  • Requests to verify counterparty information, enhanced CDD, and source of funds and source of wealth records (Forms 9 to 14)
  • Trigger event and periodic reviews set by customer risk rating, at annual, two-yearly and three-yearly intervals (Forms 15 to 16)
  • Escalation form and escalation register, counterparty non-cooperation, and unusual activity reporting and review (Forms 17 to 21)
  • Policy maintenance triggers and country risk rating updates using the Basel AML Index, FATF listings and DFAT sanctions (Forms 22 to 23)
  • Periodic effectiveness testing, independent evaluation responses and the annual report to the governing body (Forms 24 to 26)
  • AUSTRAC enrolment checklist, including updating enrolment details within 14 days of a change (Form 27)

You receive an editable Word document with [CLIENT NAME] and [Insert date] fields on the cover page, and every form built as a Word table you can complete on screen, print, or reproduce field for field in your own system. Tailor the forms to your agency's workflows before adoption, and have a suitably qualified AML/CTF adviser review the completed forms for your circumstances.

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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