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How to set up your AML/CTF program

What is an AML/CTF program?

An AML/CTF program is a documented set of policies and procedures your agency uses to identify and manage money laundering and terrorism financing risks. AUSTRAC requires every real estate agency that brokers property transactions to have one in place before 1 July 2026.

AML Simple’s program wizard guides you through each required section. The output is a program document you can use as your agency’s formal AML/CTF program.

Before you start

Have these ready:

  • Your agency’s ABN and registered business name
  • The name and role of your nominated Compliance Officer (must be senior management — see Appointing a Compliance Officer)
  • A general sense of your client types and transaction volumes

The 7 wizard steps

Log in to AML Simple, go to Program, and select Start program.

  1. Business details — your agency name, ABN, office locations, and the designated services you provide (e.g. residential sales, buyer’s agent services)

  2. Risk assessment — identify ML/TF/PF risks across four required categories: your customers, your services, how you deliver them, and the geographic areas you operate in. The wizard provides pre-filled prompts based on common real estate risk factors

  3. Compliance Officer — record who is responsible for your AML/CTF program. You must notify AUSTRAC of their name by 29 July 2026

  4. CDD procedures — document how your agency verifies client identity, when you apply enhanced due diligence, and how you handle clients who cannot provide standard ID

  5. Record keeping — confirm how you will store AML/CTF records for the required 7-year retention period. AML Simple retains records created in the platform automatically

  6. Training — record your training plan for staff: who delivers it, when, and how often it will be refreshed

  7. Review schedule — set a date to review and update your program. Annual reviews are best practice; your risk assessment must be reviewed at least every 3 years

Finishing your program

After completing all steps, AML Simple generates your program document as a PDF. Starter plans receive an AML Simple-branded document; Professional and Agency plans produce a white-labelled version with your agency’s logo and colours.

Your program is saved to your account and versioned — updates are tracked with a timestamp.

What to do next

  • Share the program with your Compliance Officer and senior management for sign-off
  • Keep it accessible so staff can refer to it
  • Update it whenever your business changes — new services, new markets, or regulatory updates

AML Simple sends a reminder when your scheduled review date is approaching.