AUSTRAC has released a real estate program starter kit to help small real estate and buyer’s agencies prepare for the incoming anti-money laundering and counter-terrorism financing reforms. 

For many agencies, this may be the first time they have had to build a formal AML/CTF program. 

That can sound heavy. But the starter kit is designed to make the process more practical. It gives eligible agencies a structured starting point for building the policies, processes and forms they will need before the new obligations begin. 

From 1 July 2026, real estate and buyer’s agents must have an AML/CTF program in place before they broker the purchase, sale or transfer of real estate. AUSTRAC refers to this as providing a designated service.   

This article breaks down what the starter kit is, who it is designed for and how agencies can use it without overcomplicating the process. 

What is AUSTRAC’s real estate starter kit? 

The real estate program starter kit is a set of guidance documents, templates and forms designed to help small real estate and buyer’s agencies customise, use and maintain an AML/CTF program. 

In plain English, it helps agencies work through: 

• what risks apply to their business 

• what policies they need 

• how AML tasks should be handled day to day 

• what information needs to be collected 

• how staff responsibilities should be managed 

Once customised, the documents work together to form the agency’s AML/CTF program. The important word here is customised. 

The starter kit is not designed to be used exactly as downloaded. Agencies need to adapt it so it reflects their business model, customers, services, risks and internal processes. AUSTRAC says the customisation process covers a four-step structure: risk, personnel, customers, then document and approve.   

Who is the starter kit designed for? 

The starter kit is designed for small real estate and buyer’s agencies that will be regulated under Australia’s AML/CTF laws. It is aimed at businesses with a relatively simple risk profile. For example, AUSTRAC says it is suitable for agencies that generally: 

• provide one designated service, being the brokering of the purchase, sale or transfer of real estate 

• have 15 or fewer personnel 

• mostly deal with individual customers who are Australian residents 

• do not regularly deal with high-risk customers 

• do not broker overseas property 

• do not sell property they own themselves, such as property developers 

• are not part of a large reporting group, foreign branch or subsidiary 

For small agencies that broadly fit this profile, the starter kit may provide a useful structure. For larger agencies or more complex businesses, it may not be enough on its own. AUSTRAC makes clear that businesses need to assess whether the starter kit is appropriate and adapt it if their services, customers or risks are more complex.   

What if your agency does not fit neatly into the starter kit? 

This is where agencies need to be careful. The starter kit is helpful, but it is not a shortcut around understanding your own business. If your agency deals with more complex customer types, high-risk customers, overseas property, property development activity, conveyancing services or other professional services, you may need to go beyond the real estate starter kit. 

The same applies if you operate across multiple offices, sit within a larger group, or have a more complex operating model. The key point is this: your AML/CTF program needs to reflect the size, nature and complexity of your business. 

That does not mean every agency needs to build something enormous. It means the program needs to match how your business actually works. 

What is included in the starter kit? 

AUSTRAC’s starter kit includes the core documents that make up an AML/CTF program. 

These include: 

A risk assessment 
This helps agencies identify the money laundering, terrorism financing and proliferation financing risks that may apply to their business. It also helps agencies determine which risks they are willing to accept and what controls are needed. 

A policy document 
This sets out what the business must do to meet its AML/CTF obligations and who is responsible for key activities. 

A process document 
This explains how AML/CTF tasks are carried out in practice. It covers the steps staff should follow and where systems or tools may support the process. 

Forms and supporting documents 
These help agencies collect information, record decisions, document escalation and demonstrate compliance. 

AUSTRAC describes the starter kit as a practical package to help businesses build their own anti-money laundering program, with tools that support compliance.   

The four main steps in the starter kit 

The starter kit is not just a bundle of forms. It follows a practical process. 

1. Customise your risk assessment 

This is the foundation of the program. Agencies need to identify which risks are relevant to their business, how significant those risks are and what controls should apply. 

For example, an agency that only works with local residential sellers may have a very different risk profile to one that regularly deals with overseas buyers, trusts, companies or high-value transactions. 

The goal is not to make every customer high risk. The goal is to understand where risk may sit and have a clear process for responding to it. 

2. Customise the personnel sections 

AML is not just about customers. It also affects staff roles and responsibilities. The starter kit asks agencies to identify who will perform AML/CTF-related duties, how those people will be trained and how their suitability will be assessed. 

For many real estate agencies, this responsibility will likely sit with the Licensee in Charge, business owner or a senior manager. 

AUSTRAC says newly regulated entities should have an AML/CTF compliance officer and train staff on their program, internal processes and ML/TF risks by 1 July 2026.   

3. Tailor the customer sections 

This is where the program starts to connect with day-to-day agency work. The starter kit helps agencies establish how they will identify customers, apply customer due diligence, assess risk and respond to higher-risk situations. 

For real estate, this is particularly important because AUSTRAC says real estate businesses are likely to provide designated services if they work as a buyer’s or seller’s agent, or if they are property developers or other businesses selling house and land packages, apartments off the plan, or blocks of land in new subdivisions.   

Customer due diligence will need to become part of the transaction workflow, not a separate afterthought. 

4. Document and approve the program 

Once the documents have been customised, they need to be approved by a senior manager. For a typical agency, that could be the Licensee in Charge, principal or business owner. This step matters because AML cannot sit as a loose collection of forms. It needs to become an approved framework that the business actually uses. 

How the starter kit works after it is customised 

Once the starter kit is customised and approved, it becomes the agency’s AML/CTF program. From there, it should guide how the business deals with customers, manages staff responsibilities and responds to risk. 

AUSTRAC explains that the customised documents and forms work together as the AML/CTF program, guiding how the business manages AML/CTF tasks and responds to ML/TF risks.   

In practice, that means the program should help answer questions such as: 

• What information do we need to collect from a customer? 

• When do we need to verify identity? 

• How do we decide whether a customer is low, medium or high risk? 

• When should an issue be escalated? 

• Who approves higher-risk situations? 

• What records need to be kept? 

This is where AML becomes operational. It moves from “we downloaded the kit” to “this is how our agency handles it”. 

How to use the starter kit without overcomplicating it 

For small agencies, the biggest risk is either doing too little or making the process far more complicated than it needs to be. The most practical approach is to work through the starter kit in stages. 

Start by confirming whether the starter kit suits your business. Then identify who will own the process internally. From there, work through the risk assessment, personnel responsibilities, customer processes and approval steps. Do not treat the starter kit as an admin task to tick off at the last minute. It should help shape how the agency will operate from 1 July. 

That means thinking about how the program fits into your existing systems, including onboarding, customer communication, document collection, staff training and record-keeping. 

What agencies should be doing now 

If you are a small agency or buyer’s agency, now is the time to review whether the starter kit is relevant to your business. A practical starting point is to ask: 

• Are we likely to be regulated? 

• Do we fit the type of agency the starter kit was designed for? 

• Who will customise and own the program? 

• What customer checks do we already complete? 

• Where do our current processes need more structure? 

• How will staff be trained before 1 July? 

These are not theoretical questions. They are operational ones. The agencies that use the starter kit well will be the ones that adapt it to their actual business, rather than treating it as a generic compliance document. 

How Under The Hammer is supporting agencies 

At Under The Hammer, we work closely with real estate professionals navigating regulatory change. 

As the AML reforms approach, our focus is on helping agencies understand what this means in practice, not just in theory, and how it fits within their broader compliance responsibilities. 

Our aim is simple: help real estate agencies turn compliance into clear, workable processes. 

This article contains general information only, based on publicly available information from the AUSTRAC website at the time of publication, and does not constitute legal, financial or compliance advice. Readers should seek independent professional advice relevant to their individual circumstances.