24/07/2026
❓ how are you adjusting with the new AML requirements ❓
In Australia, anti-money laundering (AML) obligations are expanding to include real estate professionals and conveyancers under the AML/CTF reforms. These changes are designed to prevent criminals from using property transactions to launder money.
For conveyancers and real estate agents, the key requirements will include:
* Customer Due Diligence (CDD): Verify the identity of clients before providing designated services. This includes identifying beneficial owners where companies or trusts are involved.
* Know Your Customer (KYC): Understand who your client is, the nature of the transaction, and assess the risk of money laundering or terrorism financing.
* Risk Assessment: Develop and maintain an AML/CTF risk assessment specific to your business, considering factors such as client types, services offered, delivery channels, and geographic risks.
* AML/CTF Program: Implement and maintain a documented AML/CTF compliance program that includes policies, procedures, staff training, and ongoing monitoring.
* Ongoing Customer Due Diligence: Monitor transactions and keep customer information up to date throughout the business relationship.
* Suspicious Matter Reports (SMRs): Report suspicious transactions or behaviour to AUSTRAC where there are reasonable grounds to suspect money laundering, terrorism financing, or other serious crimes.
* Record Keeping: Retain identification records, transaction records, and AML documentation for the required period (generally seven years).
* Staff Training: Ensure all employees understand their AML/CTF obligations and know how to identify and escalate suspicious activity.
* Independent Review: Periodically have your AML/CTF program independently reviewed to ensure it remains effective.
📌 Conveyancers
Conveyancers will need to:
* Verify the identity of clients and beneficial owners.
* Assess the purpose and legitimacy of the property transaction.
* Identify higher-risk clients, such as those using complex trusts, overseas entities, or politically exposed persons (PEPs).
* Maintain records and report suspicious matters where required.
📌 Real estate agents
Real estate agents will need to:
* Verify buyers and sellers.
* Conduct risk assessments for transactions.
* Monitor for unusual payment methods (e.g. large cash deposits, complex ownership structures, third-party payments without a clear explanation).
* Report suspicious matters to AUSTRAC.
📧 [email protected]
📞 9379 0877
www.oakleythompson.com
