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How to set up your AML Program

:::note Key takeaway Your AML/CTF program is the document that defines how your agency manages money laundering risk. AML Simple’s program wizard walks you through the setup in about 15 minutes and produces a PDF you can implement straight away. :::

What is an AML/CTF Program?

Every real estate agency covered by Tranche 2 must have a documented AML/CTF program. This isn’t a form you file with AUSTRAC — it’s an internal document that describes your agency’s:

  • Risk assessment (what risks you face and how you manage them)
  • CDD procedures (how you identify and verify clients)
  • Sanctions screening approach
  • Suspicious matter reporting process
  • Staff training arrangements
  • Record keeping procedures
  • Compliance Officer responsibilities

Think of it as your agency’s compliance manual. You keep it on file, implement it in your day-to-day work, and update it when things change.

Before you start

You’ll need: your agency’s legal name and ABN, office address(es), the name of your Compliance Officer, and a rough sense of the types of transactions you handle (residential sales, commercial, buyer’s agency, etc.).

Step 1: Start the wizard

Log in to AML Simple and click Set up AML Program from the dashboard, then Start program wizard. The wizard has six sections. You can save and resume at any point.

Step 2: Agency profile

Enter your legal entity name, ABN, office locations, designated services, and number of staff. This flows into your risk assessment automatically.

Step 3: Risk assessment

The wizard guides you through the four risk categories AUSTRAC requires:

  1. Customers — what types of clients does your agency work with?
  2. Services — what types of transactions do you handle?
  3. Delivery channels — how do you work with clients? (in person, online, remote)
  4. Geographic locations — where do your clients and properties come from?

For each category, you’ll rate likelihood and impact of money laundering risk. The wizard suggests ratings for typical real estate scenarios — adjust them to match your actual situation.

Step 4: Policies and procedures

Based on your risk assessment, the wizard generates draft policies covering CDD, sanctions screening, SMR filing, record keeping, and more. Review each one and confirm it reflects how your agency will operate. You can customise the text on Professional and Agency plans.

Step 5: Compliance Officer

Confirm your Compliance Officer’s details. See What is an AML/CTF Compliance Officer? if you’re unsure who to appoint.

Step 6: Review and generate

Click Generate Program. AML Simple produces a PDF — branded with your agency’s logo on Professional and Agency plans. Download it, and have it reviewed and signed off by your senior management.

After you generate

Update the program whenever your business changes — new services, new office, or changes to your risk environment. AML Simple keeps version history so you always have a record of what was in place at any point.

The AML Simple program wizard produces a compliance program document based on your inputs. It’s designed to be consistent with AUSTRAC’s Program Starter Kit structure. You are responsible for ensuring the program accurately reflects your agency’s actual operations and risks. For complex situations (multiple offices, multiple designated services, or agencies with more than 15 staff), consider seeking advice from a qualified AML professional.

Have a specific compliance question? Book a 1:1 with an AML expert for personalised guidance from a qualified compliance professional.