The AUSTRAC real estate starter kit, explained
AUSTRAC gives every newly regulated sector a starting structure for its AML/CTF program. Here is what the real estate kit contains, and the part it deliberately leaves to you.
When the Tranche 2 reforms brought new professions under the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act, AUSTRAC published program starter kits by sector. The point of a starter kit is to remove the worst part of the job, which is not the compliance itself but staring at an empty document wondering what an AML/CTF program is even supposed to look like.
There is a kit written for real estate specifically, and it is free.
What the kit is, and what it is not
The kit is a scaffold: the structure of a program, the sections it needs, and standard wording for the parts that are the same for everyone. It is not a finished program, and submitting a lightly edited template as though it described your agency would miss the point of the exercise.
“Real estate program starter kit: Getting started”
The distinction worth holding onto: the kit standardises the paperwork, and your agency supplies the judgement. AUSTRAC cannot tell you which of your clients or transaction types carry more risk, because it does not know your book.
What you get
A program structure
The document skeleton, so the sections an AML/CTF program is expected to contain are already laid out rather than invented from scratch.
Risk assessment prompts
The questions to work through when deciding what your agency's money laundering risk actually is. This is the section that carries the real weight, and it is the one that cannot be copied from anybody else.
Customer due diligence guidance
What to collect and verify, and the circumstances that call for more scrutiny rather than less. Real estate has its own timing rule for buyers, which is covered in the Tranche 2 overview.
Roles and training
Who the compliance officer is, what they are responsible for, and what staff need to know. In a small agency the compliance officer is often the principal, which is allowed, but the role still has to be named and the responsibility real.
What the kit leaves for you
Three things, and they are the three that take actual work.
Your risk assessment. Where you operate, what you sell, who buys it and which of those situations you treat as higher risk. An agency selling rural properties to local owner occupiers has a different profile from one selling off the plan apartments to offshore buyers, and the program should say so.
How the checks actually happen. A program that says clients will be verified is not the same as a process a busy agent can follow on a Saturday between opens. If verification is inconvenient it quietly stops happening, and the program becomes a document that describes a fiction.
How the evidence is kept. Customer due diligence records have to survive seven years from the end of the business relationship, which is longer than most agencies keep anything, and longer than a lot of staff stay.
Turning the kit into something you run
The gap between a written program and a followed program is where most compliance failures live, and it is rarely deliberate. The program says do the checks, the week gets busy, a contract gets signed, and nobody can later show what was verified or when.
Cleard exists for that part. Today it does one thing: it sends the client a link, they photograph their ID on their own phone and pass a liveness and face match check, and the verified result files itself against the property with a timestamped entry that cannot be edited afterwards. The wider program tooling, screening, auction day timing and reporting drafts arrive at launch.
See how the verification and audit record work.
Common questions
What is the AUSTRAC starter kit?
It is a set of templates and guidance AUSTRAC publishes for each newly regulated sector, so a business has a starting structure for its AML/CTF program instead of an empty document. There is a version written specifically for real estate. The kit supplies the sections a program is expected to contain and the standard wording for the parts that are the same for every business, leaving the judgement calls to the agency.
Is the starter kit enough on its own?
No. The kit gives you the structure and the standard wording, but the risk assessment and the decisions inside it have to reflect your actual agency: where you operate, who your clients are, what kinds of transactions you handle and which of them you consider higher risk.
Does using the starter kit make us compliant?
No. Using it makes the program easier to write, which is worth having, but compliance depends on two further things. The program has to be appropriate to your business rather than generic, and it has to actually be followed: doing the customer due diligence, keeping the records for the seven year retention period and reporting when required. A well written program that nobody applies is the most common way agencies fail.
Is the starter kit free?
Yes. AUSTRAC publishes the starter kits on its own website at no cost, and an agency does not need to buy anything, register for anything or engage a consultant to download and use them. Paid help is available from advisers and software vendors if an agency wants it, but the underlying templates and guidance are free and are the same ones those advisers work from.
How long does it take to work through?
That depends on the agency, and anyone quoting a fixed number is guessing. The template work is quick. The part that takes real time is the risk assessment, because it needs input from the people who actually deal with clients and settlements.
General information about the obligations, not legal advice about your agency.