Practical AML/CTF Compliance for the Real Estate Industry
Industry Training Consultants provides specialist compliance consultancy to the real estate sector, with a focus on AML/CTF compliance, risk management, operational processes, technology and regulatory requirements.
Our approach is based on the practical operating environment of real estate businesses.
Rather than treating AML/CTF as a standalone customer identification or transaction-monitoring exercise, we focus on how AML/CTF obligations can be incorporated into the day-to-day compliance and operational processes of a real estate business.
Our experience as real estate professionals, trainers and compliance consultants allows us to assist businesses in understanding their obligations and developing practical systems, policies, procedures and workflows to support ongoing compliance.
Our focus is implementation — not simply providing information about the legislation.
Future-Focused Compliance Consultancy for Real Estate
With the AML/CTF Tranche 2 reforms now in effect from 1 July 2026, real estate businesses are required to establish and maintain appropriate systems, policies, procedures and controls to manage their AML/CTF obligations.
An AML/CTF Program establishes the policies, procedures, systems and controls a business uses to identify, assess, manage and mitigate money laundering, terrorism financing and proliferation financing risks.
The program must be appropriate to the nature, size and complexity of the business and should be reviewed and updated when there are significant changes to the business, its risk profile or the regulatory environment.
For real estate businesses, this means AML/CTF compliance needs to become part of the broader operational environment of the agency.
That is where our property-centric approach differs.
A Property-Centric Approach to AML/CTF
Real estate businesses operate within a complex property environment involving properties, owners, tenants, buyers, sellers, agents, transactions, trust accounts, contractors and other third parties.
AML/CTF compliance therefore needs to be considered within that broader operational environment.
Our approach connects AML/CTF requirements with the processes and information already being managed within a real estate business, including:
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Risk assessments
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Customers
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Properties
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Transactions
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Ongoing customer due diligence
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Transaction monitoring
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Compliance monitoring
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Escalation
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Decisions and actions
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Record keeping
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Reporting
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Evidence and audit trails
The objective is to make AML/CTF compliance part of the way the business operates, rather than treating it as a separate ID verification or customer onboarding exercise.
AML/CTF Policy & Procedure Manual
The AML/CTF Policy & Procedure Manual provides the documented policies, procedures, responsibilities and controls your business needs to implement and manage its AML/CTF obligations.
The Manual is developed specifically for your real estate business and is designed to work alongside the AgentSafe Compliance Management System (CMS).
AgentSafe provides the operational environment in which your AML/CTF requirements can be implemented, recorded and managed — including risk assessments, compliance activities, monitoring, decisions, actions and supporting evidence.
Implementation Fee
Typically $1,500.00 to $2,500.00 + GST, depending on the size, structure and complexity of your reporting entity or reporting group.
Large reporting groups and enterprise structures are quoted on application.
What's Included
Fully Customised AML/CTF Framework
A practical AML/CTF framework developed specifically for your business, incorporating the policies, procedures, responsibilities and controls relevant to your operations.
AgentSafe Integration
The Manual is implemented alongside the AgentSafe Compliance Management System, providing a practical workflow for managing your AML/CTF compliance activities.
Operational Procedures
Clear, practical procedures designed around the way your real estate business actually operates, rather than relying solely on generic AML/CTF processes.
Compliance Officer Support
The framework provides your Compliance Officer with the structure needed to manage ongoing monitoring, escalation, reporting, reviews and compliance activities.
Audit & Training Ready
Documentation and operational records are structured to support staff training, internal reviews, compliance management and regulatory requirements.
Professional Delivery
Your completed Manual is supplied in editable Word and print-ready PDF formats, aligned with your business branding.
The AgentSafe Framework
The Policy & Procedure Manual establishes what your business must do. AgentSafe provides the operating environment in which those requirements are implemented, recorded and managed.
Together, they provide a practical framework for operating an AML/CTF program across your business.
The AgentSafe framework connects AML/CTF requirements with the operational environment of a real estate agency, including:
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Risk assessments
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Properties
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Customers
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Transactions
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Monitoring
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Escalation
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Decisions and actions
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Compliance records
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Evidence and audit trails
This provides a broader compliance management environment rather than relying solely on customer onboarding or identity verification software.
Additional AML/CTF Consultancy Support
Not every business has the same structure, risk profile or operational requirements.
Where additional assistance is required, consultancy support is available for more complex implementations, reporting groups and multi-office environments.
Support may include:
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AML/CTF implementation and reporting guidance
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Compliance audits
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Policy and procedure reviews
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Staff training aligned with AUSTRAC requirements
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AgentSafe system and workflow guidance
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Risk assessment assistance
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Assistance with complex or multi-office implementations
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Review and refinement of existing AML/CTF processes
This provides businesses with access to professional assistance where required, while maintaining a practical, self-managed compliance framework through AgentSafe.
AgentSafe Implementation & Consulting Options
1. Remote Compliance Implementation & System Walkthrough
Delivered via secure Google Meet for the agency's Compliance Officer.
The session can include:
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90–120 minute screen-share walkthrough of AgentSafe
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Configuration of AML/CTF workflows
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Configuration of property-centric risk categories
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Guidance on using AgentSafe's compliance features
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Guidance on integrating AML/CTF activities into existing workflows
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Practical assistance with the agency's compliance processes
AgentSafe's broader compliance functionality can also be incorporated, including:
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WHS compliance tools
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Material fact disclosure reporting
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Property registers
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Tradesperson and maintenance management
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Workflow automation
Pricing: $200 per hour + GST
A 50% retainer is payable prior to commencement.
Ideal for agencies subscribing to AgentSafe that want practical assistance setting up and using the system effectively.
2. Strategic Implementation & Multi-Office Projects
Designed for:
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Multi-office groups
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Franchises
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Larger reporting groups
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Businesses requiring more complex workflow integration
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Projects involving broader compliance architecture
Depending on the project, services may include:
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Executive briefings
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Workflow mapping
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AML/CTF implementation planning
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Risk and compliance framework development
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Full AgentSafe configuration
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Multi-office implementation
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Staff and Compliance Officer training
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Integration of compliance and operational workflows
Remote sessions are available for longer projects, with onsite sessions available by arrangement.
Pricing: $350–$500 per hour + GST, depending on project scope and complexity.
Travel costs are arranged separately for onsite projects.
General Support & Ad-Hoc Consultancy
For smaller or straightforward requirements, general consultancy support is available at:
$200 per hour + GST
This may include short consultations, ad-hoc support, system assistance or assistance with specific compliance tasks.
For short ad-hoc engagements, no formal consultancy agreement is required.
AML/CTF Compliance & AgentSafe Implementation Consultancy
For structured AML/CTF implementation projects:
Specialist Consultancy Rate: $350–$500 per hour + GST
Fixed implementation packages are also available for multi-user, multi-office and larger reporting group projects.
Engagement Requirements
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A formal consultancy agreement is required for structured implementation projects.
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A 50% retainer is payable prior to commencement to secure scheduling and dedicated resources.
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Post-implementation support is available on an ongoing hourly basis.
This provides flexibility for smaller support requirements while allowing more comprehensive implementation support where required.
Delivery
Consultancy services are available nationally via secure Google Meet or by phone.
Support can include access to your AgentSafe profile where required for implementation and workflow guidance.
Onsite sessions are available for multi-office and larger implementation projects by arrangement.
Compliance Guidance — Not Legal Advice
Our role is to provide practical guidance on compliance matters and assist businesses in navigating the legal and regulatory requirements, industry standards and operational expectations relevant to the real estate industry.
Our consultancy services do not constitute legal advice.
Where specialist legal advice is required, businesses should obtain advice from a qualified legal practitioner.
How to Make an Appointment
If you would like to discuss your AML/CTF requirements, implementation needs or AgentSafe configuration, contact us to arrange a consultation.
Call (02) 4001 0128
We can discuss your business structure, current compliance arrangements and the outcomes you are looking to achieve before determining the appropriate level of support.
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