Confirm your agency’s service
Table 5 item 1 covers a business brokering property sales, purchases or transfers for another person. It's worth knowing that both the buyer and the seller are customers for AML/CTF purposes, even when your agency represents only one side, and buyer’s agents are included too. It's also a good idea to check the geographical link to Australia and the legal interest involved.
For the person you represent, the agency agreement is the usual starting point for the service. For the other party, it's generally when the transaction is expected to proceed, which is typically at contract signing, so it helps to plan your checks around those events.
Direct sales by a property-selling business without an independent agent fall under a separate service, and conveyancing has its own separate requirements as well. The portal doesn’t cover those workflows. Check AUSTRAC’s real estate service definitions and timing.
Prepare and review the sale file
- Set up the agency. Start by confirming enrolment, your compliance officer, staff responsibilities, and an approved risk assessment and AML/CTF program. It's also worth checking whether AUSTRAC’s starter kit suits you, and then customising it.
- Identify the parties. Next, record the buyer, seller, entity type, representatives and relevant beneficial owners. You'll want to confirm their authority to act and collect the information your program requires.
- Complete CDD. This is where you collect identity evidence, understand the transaction and assess risk. Resolve any screening concerns and apply enhanced measures where they're needed. Keep in mind that a LINK result is part of the evidence, not an agency approval.
- Record the decision. The responsible reviewer checks the current evidence, records the reason and assigns any outstanding actions. If delayed CDD is permitted, please record the applicable conditions and deadlines, because it isn't a general exemption.
- Review changes. Changes to parties, ownership, funding or transaction circumstances can require further review, so it helps to keep decisions and follow-up work connected to the file.
When you're ready to develop your procedures, you can use AUSTRAC’s real estate starter kit, customer examples and maintenance guidance as a starting point.
Report through AUSTRAC Online
Suspicious matter reports
Please record when a reportable suspicion arose and restrict access to the matter. Terrorism-financing suspicions have a 24-hour deadline from that point, while other SMRs are generally due within three business days after the day of suspicion. Legal professional privilege can affect requirements, so it's best to get appropriate advice if it applies. Escalate concerns promptly to authorised staff and take care to protect against tipping off. Check the SMR rules, forms and deadlines.
Threshold transaction reports
A designated service involving A$10,000 or more in physical cash, or the foreign-currency equivalent, triggers a TTR, and you submit it within ten business days after the transaction day. An electronic settlement payment is not physical cash, although a cash deposit can trigger reporting before settlement. Check AUSTRAC’s TTR guidance and real estate example.
Annual compliance reports
The next reporting period is 1 July 2026 to 30 June 2027, with submission open from 1 July to 30 September 2027. An administrator submits it through your AUSTRAC Online account. Check who must report and the applicable exceptions.
Whichever report it is, please use the current AUSTRAC Online forms, and keep the submitted version, lodgement reference and receipt with the restricted reporting record. Just remember that creating a draft or downloading an export does not establish lodgement or acceptance.
Retain the evidence
Keep CDD records for seven years after the business relationship ends or an occasional transaction is completed. Transaction and program records have different retention triggers, so it's best to set retention by record type and make sure you keep access when staff or providers change. AUSTRAC’s record-keeping requirements have the full detail.
If you'd like to try it for yourself, you can start free in a couple of minutes. Every account comes with a sandbox full of sample sale files, so you can explore the whole workflow before anything real happens.