Real Estate AML Program Templates Australia — Free Download

Why you need a written AML/CTF program

Under the AML/CTF Act, every reporting entity — including real estate agencies conducting sales — must have a written AML/CTF program in place before their obligations commence on 1 July 2026.

Your program documents how your agency identifies, assesses, and manages the risk of money laundering and terrorism financing. It also sets out your procedures for CDD, staff training, suspicious matter reporting, and record-keeping.

AUSTRAC can request to see your program during a compliance assessment. Not having one — or having one that's clearly inadequate — is a serious compliance failure.

What's in SimpleAML's free templates

SimpleAML provides three Word documents that together make up a complete AML/CTF program for a real estate agency:

How to use the templates

Step 1: Complete your risk assessment first

Before you fill in your AML/CTF program, you need to understand your agency's specific risk profile. Use the Risk Assessment template — or work through the risk assessment in the SimpleAML app — to document the money laundering risks relevant to your agency's client types, transaction volumes, property types, and geographic area.

Step 2: Customise Part A

Part A covers governance. Fill in your agency name, the name of your AML/CTF Compliance Officer, your AUSTRAC enrolment number (once enrolled), and review the risk appetite and oversight sections. Most of this content will apply as-is to a typical agency — just update the highlighted fields.

Step 3: Customise Part B

Part B covers your CDD procedures. This is the most important day-to-day document. Review the verification procedures and confirm they match how your agency will actually collect and verify ID — whether that's in-person, via electronic verification services, or via certified copies.

Step 4: Get sign-off

Your AML/CTF program should be formally approved by the principal or director of the agency. Date it, sign it, and keep a copy on file. Record the approval date in the SimpleAML app.

Step 5: Brief your staff

Everyone who works on property transactions needs to understand the program. Hold a brief team meeting, walk through the key procedures, and record attendance in your training register. SimpleAML's app has a built-in training register for this.

Do I need a lawyer to write my AML program?

Not necessarily. The SimpleAML templates are designed to be used by principals and compliance officers without legal assistance. They are based on AUSTRAC's published guidance and cover the required elements of an AML/CTF program for a real estate agency.

That said, if your agency has unusual features — multiple jurisdictions, complex trust structures, or unusually high-value transactions — it may be worth a brief legal review. For most standard agencies, the templates will be sufficient with careful customisation.