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AUSTRAC obligations are live

You are already a reporting entity.

Cleard verifies your vendors and buyers and keeps the proof, starting with the deal on your desk today.

AUSTRAC compliance software for Australian real estate agents. Identity verification is live today; the rest of the toolkit arrives at launch.

Australian owned Scoped to AUSTRAC's real estate designated services
AUDIT RECORD · CASE 0417ILLUSTRATION
  1. 09:14:02Case opened14 Sample St, vendor
  2. 09:14:19Link sent to clientSMS, expires in 24 hours
  3. 09:15:07Licence capturedFront and back, on the client's phone
  4. 09:15:22Liveness check passed
  5. 09:15:24Face match 96%Against the document portrait
  6. 09:15:25Filed against the propertyEntry written, record sealed

Every entry is written once and kept for the seven year retention period. Nothing in the record can be edited after the fact.

Illustrative audit record. Sample names and addresses.

Tranche 2 status

Tranche 2 is live for real estate agents.

The reforms extended Australia's anti-money laundering and counter-terrorism financing (AML/CTF) laws to real estate. The figures below are the regulator's own.

Close to 100,000
businesses AUSTRAC said it will regulate nationwide under the reforms, up from around 19,000
Source: AUSTRAC
Enrolment
is required of every newly regulated business, and is separate from having an AML/CTF program
Source: AUSTRAC
7 years
how long customer due diligence (CDD) records must be kept
Source: AUSTRAC
High
the money laundering risk rating AUSTRAC's national risk assessment gives the real estate sector
Source: AUSTRAC

Your obligations

Every AUSTRAC obligation, and what Cleard does about it.

The Department of Home Affairs lists six key obligations for reporting entities. Here is what each one means for an agency, what Cleard does today, and what arrives at launch.

Enrol with AUSTRAC

Enrolment is a short form about your entity, the designated services you provide and your nominated compliance officer. At launch, Cleard holds those details as one record, assembles the form for copy across, and stores what you submitted and when.

Build and maintain your AML/CTF program

Risk assessment, policies, procedures and controls, written for brokering real estate rather than adapted from a banking template, and versioned so you can show what the program said on any given day. The program builder ships at launch, built on AUSTRAC's real estate program starter kit.

Initial customer due diligence

Identify and verify the customer before you provide the designated service, whether that customer is an individual, a company, a trust or a self managed super fund (SMSF). Cleard verifies individuals today with document capture, a liveness check and a face match, and attaches every case to the property so the vendor side and the buyer side sit in one file. Auction day timing arrives at launch.

Ongoing customer due diligence

Enhanced due diligence is the response when something is not clear: a screening result that needs a second look, a beneficial owner who is a politically exposed person (PEP), ownership that cannot be traced through. At launch, Cleard flags those cases automatically, with risk scoring and continuous rescreening as lists change.

Reporting

Suspicious matter reports (SMRs) and threshold transaction reports (TTRs) are the two AUSTRAC reports an agency lodges. Cleard's drafts, pre-filled from the evidence already in the case file so nothing is retyped, ship at launch.

Records

An append only, event sourced audit trail. Every verification and every status change is recorded with actor, timestamp and provider reference, and a completed record is never overwritten by a late or redelivered result. AUSTRAC requires CDD records for 7 years from the end of the business relationship, and seven year retention is in place from launch.

Identity verification is live today; the rest of the obligation set arrives at launch, on every plan. Day to day, the workflow is three steps, the pricing is per agent, and the common questions are answered below.

Built for Australian real estate

The real estate specifics, built in.

Four situations come up constantly in Australian agencies. Cleard's case model is designed around each one.

Auction day and delayed CDD

AUSTRAC allows initial customer due diligence (CDD) to be delayed where it will not be possible to complete it on the successful bidder before the auction starts. Where CDD is delayed it must be completed 28 days after the exchange of contracts, or at least 3 days before the initially agreed day for settlement, whichever is earliest. Cleard tracks both clocks from the fall of the hammer, and that lands at launch.

Your customer is the vendor and the buyer

AUSTRAC's real estate designated services table treats the customer of a brokering service as both the seller or transferor and the buyer or transferee. That means two due diligence workflows on two different clocks, the vendor at listing and the buyer at contract. Cleard attaches both cases to the one property file, so the vendor's checks and the buyer's checks sit side by side.

Trusts, SMSFs and company buyers

Buying through a family trust, a unit trust or a self managed super fund is routine in Australian property, and each one needs beneficial owner look through, not just a company search. Cleard collects the trust deed and each individual's verification and keeps them attached to the same case as the property. Automated look through from the corporate registry arrives at launch.

Foreign buyers and enhanced CDD

Foreign buyers usually trigger enhanced customer due diligence: additional identity evidence, source of funds and source of wealth, sanctions and politically exposed person screening, and a documented reason for the risk decision. Approval from the Foreign Investment Review Board (FIRB) is a separate requirement, not an AML one, but it belongs in the same file. Prompts for FIRB status, source of funds and source of wealth arrive at launch.

One thing that is not caught. AUSTRAC's definition of real estate excludes leases of 30 years or less, which is why ordinary residential property management and rent rolls sit outside the brokering designated service. The sales side of the same business is still caught. More on property managers.

How it works

From new listing to audit ready record.

Three steps, the same every time, logged as you go.

STEP 01
NEW CASE
Buyer full name
Buyer · individual
Send verification

Open the case

Choose the property, the side of the transaction and the entity type. Cleard sets the document requirements for that entity type and tells the client exactly what to photograph, so nobody is deciding what to collect on the spot.
STEP 02
Verify ID for 88 Sample Cres
Capture

The client verifies on their phone

They get a link, photograph their ID and complete a liveness check. The verified identity, the captured evidence and the face match score file themselves against the case. Sanctions and PEP screening runs on the same result at launch.
STEP 03
Buyer
Contract · 88 Sample Cres
Verified · Audit logged

The record closes itself

Verification status, the evidence captured, the face match score and a timestamped audit entry for every step, all held against the case.

Compare

Spreadsheets, a generic AML platform, or Cleard.

Three ways to meet the same obligations.

Writing your AML/CTF program

SPREADSHEETS AND PDFS

A blank document and a long weekend

GENERIC AML PLATFORM

Ask which industry the program template was written for

CLEARD

Real estate scoped workflow today, program builder at launch

Verifying a vendor and a buyer

SPREADSHEETS AND PDFS

Certified copies and email chains

GENERIC AML PLATFORM

Ask how two customers on one transaction are handled

CLEARD

Vendor and buyer cases attached to one property file

Auction day timing

SPREADSHEETS AND PDFS

Tracked by hand, if anyone remembers

GENERIC AML PLATFORM

Ask whether the 28 day and 3 day delayed CDD clocks are tracked

CLEARD

Delayed CDD clock tracking at launch

Sanctions and PEP screening

SPREADSHEETS AND PDFS

Manual searches of public lists, screenshots as evidence

GENERIC AML PLATFORM

Ask whether screening is included and how rescreening works

CLEARD

Screening wired into the case workflow, live at launch

Seven year records

SPREADSHEETS AND PDFS

A shared drive and hope

GENERIC AML PLATFORM

Ask how the 7 year retention period is enforced

CLEARD

Append only audit trail on every case and status change

When AUSTRAC asks

SPREADSHEETS AND PDFS

Days of reassembling evidence

GENERIC AML PLATFORM

Ask what a complete case file export looks like

CLEARD

Case file export at launch

Cost

SPREADSHEETS AND PDFS

Staff hours

GENERIC AML PLATFORM

Depends on the platform, ask for a quote

CLEARD

$49 per agent per month

If the Cleard line is the one you want, the pricing is per agent or per office, in Australian dollars.

Australian ownedScoped to AUSTRAC's real estate designated servicesLiveness and face match on every ID checkAppend only audit trail on every case

Pricing

Pricing built for agencies, not enterprises.

All prices in Australian dollars.

Solo

$49
per agent, per month
Get started
30 verifications per agent each month
Vendor and buyer onboarding
Liveness and face match on every ID check
Append only audit trail on every case

Office

$199
per office, per month
Get started
Everything in Solo
Unlimited verifications
Trust, SMSF and company onboarding
Trust deed and beneficial owner collection on entity buyers
One case list for the whole office, with named user accounts at launch
Enhanced due diligence flagging on screening and ownership results, at launch

Network

Custom
multi office groups
Talk to us
Multi office groups are priced individually. Tell us how your network is structured and we will scope the rollout with you.
Everything in Office
Named account contact

Coming at launch, on every plan: the AML/CTF program builder, sanctions and politically exposed person screening, auction day delayed due diligence tracking, and suspicious matter and threshold transaction report drafts. Live today: identity verification with the audit trail. No launch date is promised; the FAQ below covers what at launch means.

FAQ

AUSTRAC compliance for real estate agents, answered.

Not covered here? Get in touch.

Do real estate agents need to register with AUSTRAC?

Yes. Under the Tranche 2 reforms, agencies that broker the sale, purchase or transfer of real estate provide a designated service and are AUSTRAC reporting entities. Enrolling with AUSTRAC and having an AML/CTF program are separate requirements, and an agency needs both.

What is the AUSTRAC enrolment deadline, and what happens if we missed it?

AUSTRAC set an enrolment deadline for newly regulated businesses when the reforms commenced. If your agency has not enrolled, enrol now rather than waiting for advice. Enrolment itself is a short form covering your business, the designated services you provide and your compliance officer. The larger exposure is usually the AML/CTF program, because AUSTRAC expects one in place before you broker a sale.

What is AML for real estate agents, and which of my services are caught?

The caught service is brokering the sale, purchase or transfer of real estate. Selling agents, buyer's agents and agencies acting on a transfer are all in scope, and due diligence is owed on both sides of the same transaction.

Can I verify a buyer after the auction, or does it have to happen before the hammer falls?

AUSTRAC allows initial customer due diligence (CDD) to be delayed where it will not be possible to complete it on the successful bidder before the auction starts. Delayed CDD must then be completed 28 days after the exchange of contracts, or at least 3 days before the initially agreed day for settlement, whichever is earliest. On a quick settlement the 3 day rule bites first, so work from both dates. Tracking both clocks per case arrives at launch.

Who is my customer under the AML/CTF Act, the vendor or the buyer?

Both. When you broker the sale, purchase or transfer of real estate, AUSTRAC treats the customer as both the seller or transferor and the buyer or transferee. In practice that is two due diligence workflows on two different clocks, the vendor at listing and the buyer at contract. Cleard holds both cases against the one property file so neither side gets missed.

Do property managers and residential rentals need an AML/CTF program?

Ordinary residential property management generally sits outside the brokering designated service, because AUSTRAC's definition of real estate excludes leases of 30 years or less. If your rent roll only handles standard residential leases, that work is not the caught service. If the same entity also brokers sales, the sales side is caught and needs a program.

How do agents actually run AML checks on buyers and sellers?

You collect and verify identity information before you provide the designated service, screen the customer against sanctions and politically exposed person lists, set a risk rating, and keep the evidence. For companies, trusts and self managed super funds you also identify the beneficial owners. Cleard sends the client a link, collects and reads their documents on their phone, runs a liveness and face match check, and files the verified result against the case.

Do we need an AML/CTF program even if we rarely see high risk clients?

Yes. AUSTRAC states that 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. The program is proportionate to your risk, so a small suburban agency writes a shorter one than a prestige agency handling foreign buyers, but every agency needs one.

How long do we have to keep AML records?

Seven years. AUSTRAC requires customer due diligence records to be kept for 7 years from when the business relationship ends, and AML/CTF program records for 7 years after the record is no longer relevant to demonstrating compliance. Cleard writes every case to an append only audit trail, so the record you produce later is the record that was made at the time.

How do we verify a buyer purchasing through a family trust, unit trust or SMSF?

You identify the entity itself, then look through to the people behind it: trustees, beneficiaries, settlors and anyone who controls the trust, plus the beneficial owners of a corporate trustee. Cleard collects the deed and each person's verification against the one case today; automated look through from the corporate registry arrives at launch.

What extra checks apply to a foreign buyer, and where does FIRB fit?

Foreign buyers usually trigger enhanced customer due diligence: more identity evidence, source of funds and source of wealth, sanctions and politically exposed person screening, and a documented reason for your risk decision. Approval from the Foreign Investment Review Board (FIRB) is a separate foreign investment requirement rather than an AML obligation, but it belongs in the same file. Cleard's prompts for FIRB status, source of funds and source of wealth arrive at launch.

How much does AML compliance software for a real estate agency cost?

Cleard is $49 per agent per month on Solo, which includes 30 verifications per agent each month, or $199 per office per month on Office for unlimited verifications. Multi office groups are priced individually. All prices are in Australian dollars. There is no separate charge for liveness and face match checks or for the audit trail, and sanctions and PEP screening is included at no extra charge from launch.

What happens if we go past Solo's 30 verifications in a month?

Solo includes 30 verifications per agent each month. Past that, the intended step is the Office plan, which is $199 per office per month with unlimited verifications; there is no published per verification overage charge. If you are unsure which plan fits your volume, ask before you commit and we will work it through with you.

Several features say at launch. What does that mean, and when is launch?

At launch describes capabilities that arrive when Cleard becomes generally available. What is live today is identity verification: liveness checked ID capture with a face match result, filed in an append only audit record. The AML/CTF program builder, sanctions and politically exposed person screening, delayed due diligence tracking and report drafts are not available yet, and we deliberately do not promise a date rather than set one and miss it. If a particular capability decides your purchase, ask and you will get its current status.

How long does it take to set our agency up?

There is no implementation project. Cleard is pre-launch, so onboarding starts with an email to us. Once your agency is set up, running a check means opening a case, choosing the entity type and sending the client a link; the client verifies on their own phone and there is nothing for either side to install. The genuinely slow part of AML/CTF compliance is writing your program and risk assessment, and that work is yours whichever software you use.

Where is our clients' ID data stored, and who can see it?

Identity documents, liveness captures and match results are held against your agency's own cases, and are shared with the specialist verification providers only to perform the check you asked for. Cleard does not sell personal information and does not use identity documents or biometric captures for advertising, profiling or training models. Data residency and the full provider list are still being finalised; the privacy page states what is settled and names what is not, rather than claiming certifications in advance.

Are we locked into a contract, and how do we cancel?

Plans are priced monthly, in Australian dollars. Contract length, notice periods, service levels and liability are still being finalised, and the terms page deliberately names each one as open rather than inventing them. If your agency needs those terms settled before committing, ask and you will get the current position, including where the position is that it is not settled yet.

Get your agency AUSTRAC ready.

Liveness checked ID verification today, the full obligation set at launch, from $49 per agent per month.