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AML/CTF staff training for real estate agencies.

Real estate agents who act for a buyer or seller, and developers who sell without independent agents, are regulated from 1 July 2026. Each person who does AML/CTF work needs initial and ongoing training that fits their role. Property is rated high risk, so agents must know the red flags.

Sources for this answer
  • AUSTRAC says businesses that provide the newly regulated services "will be regulated by us from 1 July 2026". [S36]
  • AUSTRAC: real estate businesses are likely to provide designated services if they work as a buyer’s or seller’s agent, or are a developer selling house and land packages, apartments off the plan or blocks of land without independent agents. [S8]
  • AUSTRAC: its national risk assessment "found the real estate sector poses a high money laundering risk in Australia". [S37]
  • AUSTRAC: "You must provide initial training at the start of a person’s employment or engagement. You must also provide ongoing training." [S1]

Who in an agency needs training?

  • Sales agents and property managers who deal with buyers and sellers: the front-line track.
  • Principals and directors who approve the program: the senior manager track.
  • The person appointed AML/CTF compliance officer: the compliance officer track.
  • Administration staff who handle payments or records: the all-staff track at least.
Facts and sources for this part
  • AUSTRAC: "All personnel in customer-facing roles need an awareness of indicators of suspicious activity and your reporting procedures." [S1]
  • AUSTRAC: you may give general training to all personnel, but if roles have different AML/CTF functions and risk levels, "you must include appropriate training for individuals exposed to these different risks". [S1]

What does AUSTRAC list as real estate red flags?

  • A buyer who avoids face-to-face meetings or is secretive.
  • Part of the price paid in cash to the agent.
  • A purchase in the name of a third party with no clear reason.
  • A sudden change of ownership close to settlement.
  • Sale proceeds sent to an unrelated third party.
Facts and sources for this part
  • AUSTRAC real estate red flags: a customer who "avoids face-to-face meetings" or is "obstructive or secretive in their dealings with you". [S37]
  • AUSTRAC real estate red flag: a customer who "makes a full or partial payment of the property purchase price in cash to the real estate agent". [S37]
  • AUSTRAC real estate red flag: a customer who buys "in the name of a third party, relative or a minor with no legal or economic reason". [S37]
  • AUSTRAC real estate red flag: a customer who "asks for a sudden change of ownership without a legitimate reason, especially close to settlement". [S37]
  • AUSTRAC real estate red flag: a customer who "directs sale proceeds to an unrelated third party". [S37]

Which lessons fit?

Start with the duty, then red flags. Front-line staff add customer due diligence and records.

  1. Lesson 1The training duty, and what it means for you3 min
  2. Lesson 3Red flags in your sector3 min
  3. Lesson 4Suspicious matter reports and tipping off3 min
  4. Lesson 2Knowing your customer: due diligence3 min
Facts and sources for this part
  • AUSTRAC: "Real estate professionals are often the first contact point for criminals trying to launder money." [S37]

A caution from AUSTRAC

AUSTRAC’s poor-practice example is an agency whose outside training did not cover real estate risks and whose business did not track completion. The fix is sector examples and a register.

Facts and sources for this part
  • AUSTRAC’s poor-practice example: a real estate agency’s outside training vendor course "doesn’t cover ML/TF risks faced by the real estate industry" and the business "doesn’t track completion, schedule refresher sessions, or confirm if personnel understand and can apply the content". [S6]
  • AUSTRAC expects you to "use a register to record completion dates and track when further training is due". [S1]