AML/CTF 2026: How Real Estate Agencies Can Build a Compliance Back Office Before July

Real estate agencies have until July 2026 to enrol with AUSTRAC and meet their obligations under Australia’s expanded Anti-Money Laundering and Counter-Terrorism Financing regime.

For most agencies, this is new territory. The requirements that apply from July include maintaining a documented AML/CTF program, verifying customer identity, monitoring transactions, and keeping records for seven years. None of this is optional, and the ongoing admin burden is significant.

Most principals have already accepted that compliance is coming. The question is how to handle the recurring compliance work without pulling agents away from sales, and without adding a specialist compliance officer to the payroll.

What the July 2026 obligations mean in practice

The AML/CTF reforms that apply to real estate agencies from 1 July 2026 sit within the Tranche 2 expansion of Australia’s existing AML regime. Agencies become reporting entities under the law, which creates a set of standing obligations that recur across the life of the business.

The specific tasks that arise include:

• Enrolling with AUSTRAC before July 2026
• Developing a written AML/CTF program that documents how the agency identifies and manages risk
• Conducting customer due diligence (CDD) on relevant clients: verifying identity, understanding the nature of relationships, and assessing risk level
• Monitoring transactions and retaining records of what was verified, when, and how
• Reporting suspicious matters and threshold transactions to AUSTRAC where required
• Reviewing and updating the program at least annually

The documentation and monitoring components are where most of the recurring admin sits. Customer due diligence has to happen before transactions proceed. Records have to be stored in a retrievable format for seven years. The program has to be maintained and kept current.

Which parts are repeatable admin and which require judgement

Breaking the compliance workload into two categories makes the staffing question much cleaner.

Some parts of AML/CTF compliance require genuine judgement: deciding whether a matter is suspicious, determining whether enhanced due diligence applies, classifying risk for specific clients. These decisions stay with a nominated compliance officer, typically a principal or senior staff member.

A large portion of the work is repeatable and documented. This includes:

• Collecting identification documents from clients before transactions proceed
• Cross-checking documents against a standard verification checklist
• Recording completed verifications in the agency’s system
• Filing completed CDD forms and maintaining the seven-year record trail
• Preparing compliance summaries for the compliance officer’s review
• Monitoring for overdue verifications and following up on outstanding documents
• Updating the AML/CTF procedures document when processes change

This work has a clear shape: a checklist, a workflow, a defined handoff point. That is the profile of work that transfers cleanly to a structured offshore role.

What an offshore compliance coordinator does in an agency

The compliance coordinator role is built around documented process: collecting the right documents, checking them against clear criteria, recording the outcomes, and flagging anything outside the checklist for the principal to review.

In practice, the daily and weekly tasks look like this:

• Checking the verification queue each morning for outstanding CDD items
• Contacting clients via email to request identity documents ahead of settlement dates
• Cross-referencing received documents against the agency’s standard verification checklist
• Updating the CRM or compliance system to mark verifications complete
• Filing documents in the correct folder structure for the seven-year retention period
• Running a weekly compliance status summary across active transactions for the nominated compliance officer
• Drafting the annual program review documentation for the principal to review and sign off

The compliance officer makes the calls that require judgement. The coordinator handles the tracking, the follow-up, and the paper trail.

How to get this in place before July

Three things need to be in place before a compliance coordinator can operate effectively.

A written AML/CTF program. This is a legal requirement and the foundation the coordinator works from. If the program does not exist, writing it is the first task. Legal and compliance specialists have templates that can accelerate this considerably. The coordinator works from the program; they cannot replace the step of creating it.

A verification checklist and CDD workflow. The coordinator needs a documented process: which documents are acceptable, in what format, for which client types. The checklist does not need to be long. It needs to be clear enough that the coordinator can work through it consistently and flag anything that does not fit.

A record-keeping system. Documents collected and verifications completed need to live somewhere retrievable for seven years. This can be a folder structure in Google Drive or SharePoint, or a field in the agency’s existing CRM. The system matters less than the discipline of using it consistently.

With these three elements in place, onboarding an offshore coordinator is straightforward. The work is documented. The handoff points are clear. The coordinator follows the process; the compliance officer reviews and decides on anything flagged.

Starting now, not in June

Agencies that wait until June to think about staffing will find themselves building both the program and the process simultaneously, under deadline pressure, with no room for onboarding time.

The practical sequence is to start the documentation work now. Write the AML/CTF program with a compliance specialist. Map the CDD workflow as part of that process. Design the record-keeping system. When the program is ready, the coordinator role brief writes itself from the task map.

HIPPO works with agencies to scope and recruit offshore compliance coordinator roles through a structured design process. The role brief is built from a clear task map. The specialist starts with documented work.

If you want to talk through how a compliance coordinator role would fit your agency’s current setup, a connect session is the right first step. Book a Connect Session