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AML/CTF compliance overview
Welcome to SimpleAML for Real Estate
Before you can record your first transaction, set up your agency profile. It only takes a couple of minutes and you'll need it for AUSTRAC enrolment.
Getting Ready for 1 July 2026
Complete all 4 steps before your obligations commence
Transactions
0
Total CDD records
High Risk
0
Require enhanced CDD
SMRs Filed
0
Suspicious matter reports
Staff Vetted
0
Personnel on record
Recent Transactions
Transactions
0
Total CDD records
High Risk
0
Require enhanced CDD
SMRs Filed
0
Suspicious matter reports
Staff Vetted
0
Personnel on record
Recent Transactions
Listing Register
All CDD records — seller and buyer per property
| Property | Method | Value | Status | Seller CDD | Buyer CDD | Deadline | Risk | Agent |
|---|
New Listing
Complete CDD for seller at listing — return to add buyer CDD when known
1
Transaction Setup
Property details and sale method — drives CDD deadlines
Private Sale — Buyer CDD Timing
Buyer CDD must be completed before exchange of contracts. Enter dates as they become known — you can update settlement date if it changes.
Auction — Buyer CDD Timing
Buyer CDD must be completed within 28 days of exchange, or before settlement — whichever is earlier. Enter all dates as they become known. Update settlement date if it changes.
2
Seller CDD
Required at listing — always direct verification (no reliance available for sellers)
⚠ Seller CDD is due at listing — complete before or when signing the agency agreement
Onboarding Information
Representative Details
Identity Verification
Directors — DVS, PEP & Sanctions required for each
Beneficial Owners (≥25% shareholding)
Trustees — DVS, PEP & Sanctions required for each
Individual Trustees — DVS, PEP & Sanctions required for each
Corporate Trustee Directors
Fund Members (beneficial owners)
Risk Assessment
⚠ Enhanced CDD Required — High Risk Customer
AMLCO Written Approval Required
High risk customers require written approval from your AML/CTF Compliance Officer before proceeding. Document this approval in your records.
3
Buyer CDD
Complete by the deadline shown below
Select transaction type and enter dates above to see buyer CDD deadline
Direct verification required in SimpleAML v1
Legal reliance (using the buyer's conveyancer's CDD) is available under the AML/CTF Act but is not yet supported in SimpleAML. If you wish to use legal reliance, document it manually and retain written confirmation from the conveyancer.
How to use legal reliance manually →
Onboarding Information
Representative Details
Identity Verification
Directors — DVS, PEP & Sanctions required for each
Beneficial Owners (≥25% shareholding)
Trustees — DVS, PEP & Sanctions required for each
Individual Trustees — DVS, PEP & Sanctions required for each
Corporate Trustee Directors
Fund Members (beneficial owners)
Risk Assessment
⚠ Enhanced CDD Required — High Risk Customer
AMLCO Written Approval Required
High risk customers require written approval from your AML/CTF Compliance Officer before proceeding.
4
Transaction Risk & Reporting
Red flags, overall risk, TTR and SMR decisions
Red Flag Checklist — check any that apply
Red flags identified — consider an SMR
One or more red flags have been checked. Review whether you have reasonable grounds to suspect money laundering or terrorism financing. If so, you must file a Suspicious Matter Report with AUSTRAC. Remember: do not tip off the buyer or seller.
Low: up to 3 years · Medium: up to 2 years · High: sooner
Threshold Transaction Report (TTR)
A TTR must be filed with AUSTRAC if a customer pays $10,000 or more in physical cash (banknotes or coins). Electronic bank transfers do not trigger a TTR.
Suspicious Matter Report (SMR)
⚠ Tipping-off prohibition — s.123 AML/CTF Act
It is a criminal offence to disclose that an SMR has been or may be filed. Do not tell the buyer, seller, conveyancer or any other party. Penalties include up to 2 years imprisonment.
Record keeping: All CDD records must be retained for 7 years from the end of the business relationship (s.107 AML/CTF Act 2006). Do not delete settled transaction records.
Training Register
AML/CTF training records — required for all staff performing AML/CTF functions
Log Training Record
Staff must be added in Staff Vetting first. Add staff →
CDD/transaction roles: ~12 months · All others: as needed
Setting up your agency? Once you've logged training for all staff, head back to the dashboard to complete the remaining setup steps.
| Staff Member | Training Type | Date | Next Refresh | Assessment | Status |
|---|
Staff Vetting
Personnel due diligence — required before staff perform any AML/CTF functions
Who needs to be vetted?
Anyone who performs AML/CTF functions must be vetted before they start — this includes all sales agents, admin staff who handle CDD forms, and your AMLCO. The level of checking is tailored to the risk of the role. Your AMLCO and anyone with trust account access require more thorough checks.
Setting up your agency? Once you've vetted all staff, head back to the dashboard to complete the remaining setup steps.
Staff Vetting Record
Checks Performed
Set based on role risk — sooner for AMLCO or if role/risk changes
| Name | Role | Level | Vetted | Skills | Integrity | Next Review | Status |
|---|
Agency Profile
Complete all fields — this information is needed for AUSTRAC enrolment
Agency Identity
AUSTRAC requires the names and contact details of all directors (if a company) or partners (if a partnership).
Contact & Location
For most agents: 1 July 2026
Includes all admin, agents and contractors. AUSTRAC starter kit is for ≤15 staff.
Memberships & Trust Account
Franchise networks and corporate groups may form a reporting group. Most independent agencies select "No".
Principal / Licensee in Charge
AML/CTF Compliance Officer (AMLCO)
Your AMLCO must be a fit and proper person — typically your Licensee in Charge, Principal or a senior manager. You must notify AUSTRAC of your AMLCO by 29 July 2026. For small agencies, the LIC is usually also the AMLCO.
Agency Risk Assessment
ML/TF/PF risk assessment — required before finalising your AML/CTF Program
Setting up your agency? Once you've completed and saved the risk assessment, head back to the dashboard to track your progress.
What this is: A documented assessment of the money laundering, terrorism financing and proliferation financing (ML/TF/PF) risks your agency faces. Your AML/CTF Program must be built on this assessment. AUSTRAC's starter kit includes a template — complete it, then record your findings here.
Transaction & Property Risk
Consider: high-value sales, commercial property, off-market transactions, unusual settlement terms, third-party payments.
Customer Risk
Consider: foreign buyers/sellers, PEPs, companies, trusts, SMSFs, customers unknown to the agency.
Proliferation Financing (PF) Risk
PF is the financing of weapons of mass destruction. Required under the reformed AML/CTF Act. All agencies must document PF exposure and controls regardless of size.
Geographic Risk
Consider: overseas buyers/sellers, foreign-sourced funds, customers from FATF high-risk jurisdictions. Check: FATF list · DFAT Sanctions
Payment & Funding Risk
Real-estate-specific risk. Consider: cash offers, cryptocurrency, third-party payments (funds from someone other than the buyer), unusual deposit structures.
Overall Agency Risk Rating
AML/CTF Program
Document your program and record senior manager approval
Setting up your agency? Once you've recorded program approval, head back to the dashboard to complete the remaining setup steps.
What this is: Your AML/CTF Program is the documented set of policies, procedures and controls your agency uses to manage ML/TF/PF risks. It must be in place before 1 July 2026 and approved by a senior manager. Use AUSTRAC's real estate starter kit to build it, then upload and record approval here.
Program Documents
The AUSTRAC starter kit produces two documents — a Policy document (what your rules are) and a Process document (how staff carry them out). Upload both once customised. Stored locally in your browser only.
Policy Document
Click to upload Policy PDF or Word
Process Document
Click to upload Process PDF or Word
Program Checkpoints
Tick each section as you complete it in your Policy document. These match the sections in AUSTRAC's real estate starter kit.
Part A — Governance & accountability
AMLCO role, senior manager accountability, governing body notification, risk appetite
Part B — Initial CDD procedures
Seller and buyer identification and verification — individuals, companies, trusts, SMSFs
PEP & sanctions screening procedures
Process for screening all customers against PEP lists and DFAT/OFAC sanctions lists
Escalation & Enhanced CDD policy
When to escalate to AMLCO, enhanced CDD steps, written senior manager approval for high-risk
Ongoing CDD & monitoring policy
Monitoring between exchange and settlement, updating customer risk ratings, unusual behaviour
Red flag indicators documented
Suspicious indicators specific to real estate — cash offers, third-party funds, unusual structures
Tipping-off & SMR procedures
How to file an SMR, non-disclosure obligations (s.123 AML/CTF Act), TTR thresholds
Proliferation financing (PF) controls
PF risk assessment referenced, DFAT consolidated list screening procedures
Record keeping procedures
What records to keep, retention period (7 years), how records are stored and accessed
Training program documented
Annual AML/CTF training schedule, roles and frequency for all staff levels
Risk assessment referenced
Agency ML/TF/PF risk assessment attached or cross-referenced in the program
0 / 11 complete
Senior Manager Approval
The AML/CTF Program must be formally approved by a senior manager before 1 July 2026. The governing body must be notified. This record is your audit evidence.
✓ Program Approved
Annual Review
Your AML/CTF Program must be reviewed at least annually, and whenever your business circumstances change significantly (new services, new high-risk customer types, regulatory changes).
First annual compliance report to AUSTRAC will be due in 2027 for Tranche 2 entities. Your program review records will be needed at that time.
AUSTRAC Enrolment
Enrolment opens 31 March 2026 · Deadline 29 July 2026
Pre-Enrolment Readiness
Steps 1–5 must be complete before you can enrol
0%
Enrolment Status
Designated Services
Tick all services you provide — you'll declare these when completing your enrolment on AUSTRAC Online.
Fit & Proper Declaration
AUSTRAC's enrolment form requires you to declare whether the business or key personnel have been subject to adverse proceedings. Answer both questions honestly — false declarations are a serious offence.
Industry Levy
AUSTRAC's enrolment form asks a single threshold question about your earnings to determine levy obligations.
For the vast majority of independent real estate agencies the answer is No. If you answered Yes, you may be subject to the industry contribution levy — speak with your accountant.
Annual Compliance Report (ACR)
All enrolled entities must submit an ACR to AUSTRAC each year, reporting on their AML/CTF compliance activities.
First ACR due 2027 — covering the period from 1 July 2026. AUSTRAC has not yet confirmed the exact due date. Once announced, record it below.
Check AUSTRAC for updates →
Check AUSTRAC for updates →
Audit & Review
Generate your AML/CTF compliance evidence report
What is this report?
The AML/CTF Compliance Evidence Report is a printable PDF document that draws all your SimpleAML data together into one structured compliance record. It is not submitted to AUSTRAC — it is held by your agency as evidence of compliance.
The report has two parts:
Part A — Annual Evidence covers enrolment, program, risk assessment, governance, your listing CDD register, training and staff vetting.
Part B — Evaluation Support includes an auto-generated gap analysis, CDD timeliness check, high-risk transaction summary, program adequacy checklist, and a blank independent evaluator declaration page.
Part A — Annual Evidence covers enrolment, program, risk assessment, governance, your listing CDD register, training and staff vetting.
Part B — Evaluation Support includes an auto-generated gap analysis, CDD timeliness check, high-risk transaction summary, program adequacy checklist, and a blank independent evaluator declaration page.
When to generate it
✅
Before 1 July 2026 — when your program is complete and approved. Print and file as your baseline compliance record.
📅
Annually — after completing your annual internal compliance review.
🔍
Three-year independent evaluation — first due approximately 2029. Provide Part B to your evaluator.
⚠️
AUSTRAC audit or enquiry — have a current report ready to provide on request.
👤
AMLCO or principal agent changes — generate a report capturing the compliance state at the time of transition.
Generate Report
The report reads your current SimpleAML data and opens in a new tab. Use your browser's print function to save as PDF. Select Portrait, A4.
Opens report-realestate.html in a new tab. The print dialog will open automatically.
7-Year Retention Requirement
Under s.107 AML/CTF Act, all CDD records and compliance documentation must be retained for a minimum of 7 years from the end of the business relationship.
Store your generated PDF reports securely. Do not delete records from SimpleAML until the 7-year period has passed.
Store your generated PDF reports securely. Do not delete records from SimpleAML until the 7-year period has passed.
Independent Evaluation
The three-year independent evaluation (s.159 AML/CTF Act) must be conducted by someone who is independent of the agency — not the AMLCO, not the principal.
First evaluation due: Approximately 2029 for new Tranche 2 entities. Part B of the report contains a structured evaluator declaration page for them to complete and sign.
About & Support
Product information, help and data management
About SimpleAML
RE
SimpleAML · Real Estate
Tranche 2 — Real Estate Edition · v1.0
Free AML/CTF compliance tool for Australian real estate agents. Helps you prepare for and maintain compliance with AUSTRAC obligations under Tranche 2 legislation, effective 1 July 2026.
Developed by
Click Seed Pty Ltd
ABN 87 656 256 567 · Australia
Danger Zone
Permanently deletes all your agency data — profile, staff, training, risk assessment, program, enrolment and all listing records. This cannot be undone. Export a backup first.
Support & Resources
Data & Backup
Your data is stored locally in this browser. Export a backup regularly — especially before clearing data or switching devices.
Legal Disclaimer
7-Year Record Retention — Under s.107 AML/CTF Act, all CDD records must be retained for a minimum of 7 years from the end of the business relationship.
This tool is provided for compliance assistance only and does not constitute legal advice. Users are responsible for ensuring their own compliance with AUSTRAC requirements. Click Seed Pty Ltd makes no warranty as to the accuracy or fitness for purpose of this tool. Seek independent legal or compliance advice where required.
This tool is provided for compliance assistance only and does not constitute legal advice. Users are responsible for ensuring their own compliance with AUSTRAC requirements. Click Seed Pty Ltd makes no warranty as to the accuracy or fitness for purpose of this tool. Seek independent legal or compliance advice where required.