AML Compliance Software for Real Estate Agents

AML Smart Guard is AML/CTF compliance software built specifically for Australian real estate agents, buyers’ agents and property developers, combining digital identity and business verification, risk assessment and transaction monitoring in one platform.

What AUSTRAC expects from real estate

From 1 July 2026, AUSTRAC treats real estate agencies, buyers’ agents, developers, and conveyancers as gatekeepers, not just deal-makers. AML Smart Guard’s program covers:

A documented ML/TF risk assessment matched to how the agency actually lists, markets, and settles property.
Customer due diligence (CDD) on both buyers and sellers.
Enhanced due diligence where a transaction or party is higher-risk.
Ongoing monitoring and escalation of red flags.
Timely suspicious matter reporting to AUSTRAC.

AUSTRAC enrolment

Confirming which designated services apply

A named compliance officer

With board-level accountability with appropriate senior management oversight.

A written, risk-based AML/CTF program

Built from a documented ML/TF risk assessment.

Customer due diligence (CDD)

Carry out customer due diligence (CDD) and enhanced CDD (ECDD): Identify and verify customers and beneficial owners before or at the time of providing designated services, understand the purpose and nature of the relationship, and apply additional checks for higher‑risk situations (for example PEPs, high‑risk countries, complex or opaque structures, unusual transactions).
Keep records: Make and retain records of CDD, transactions, risk assessments, program documents, training and AUSTRAC reports for at least 7 years, in a form that can be produced promptly on request.

Ongoing due diligence

Monitor customers and transactions on an ongoing basis: Monitor business relationships and transaction activity to detect unusual or suspicious patterns, update risk ratings when circumstances change, and use that monitoring to decide when to apply ECDD or exit relationships.

Reporting suspicious matters

Report to AUSTRAC: Lodge suspicious matter reports (SMRs) when you suspect a person or transaction may be linked to crime or terrorism financing, and submit any other required reports (for example threshold transactions, international funds transfers or sector‑specific returns) within statutory timeframes.

Which plan fits my agency?

Agency profile	Recommended plan	Why
Sole agent or small independent agency	Flex/Bespoke ($99/mth base)	Pay-as-you-go CDD screening without a large fixed cost
Mid-size agency, regular settlements	Standard ($349/mth) or Scaled ($549/mth)	Fixed screening allowance (20 to 40/mth) plus training packs
Franchise group or developer with multiple offices	Enterprise ($949/mth)	Unlimited users, dedicated account manager, ~80 screens/mth

A common mistake is treating identity verification as the end of the AML process. In a property transaction, a customer’s risk profile and circumstances can change between onboarding and settlement, so agencies need a process in place to catch relevant changes, unusual activity and red flags throughout the transaction, not just at the start.

What our clients say

If your business is…	Start here
An exchange handling fiat on/off-ramps	Standard or Scaled plan, travel-rule screening switched on from day one
A wallet provider or PSP with high transaction volume	Scaled or Enterprise, for the higher monthly CDD screen allowance
A stablecoin or token issuer still defining its risk profile	Flex/Bespoke, to right-size the program before committing to a tier

“AML Smart Guard has transformed the way we approach our AML/CTF compliance. The platform is intuitive, efficient and provides us with a clear and streamlined process for managing our KYC, KYB and ongoing compliance requirements.

The solution has significantly reduced the complexity and administrative burden associated with AML compliance, while giving us greater confidence that our obligations are being managed effectively.”

– Auctioneer, Area Specialist

Frequently asked questions

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What should a real estate agency focus on when designing its AML program?

Build a simple, risk-based program that matches how the agency lists, markets, and settles property: map designated services, define the risk assessment, set CDD and enhanced-CDD triggers, and train staff on the day-to-day process.

What does AUSTRAC enrolment look like for an agency?

Confirm scope, appoint a compliance lead, complete online enrolment, customise the AML/CTF program, then embed the controls into the agency’s existing listing and settlement systems.

What does live CDD and monitoring look like in a property transaction?

Verifying buyers and sellers, understanding source of funds, monitoring the file for red flags through to settlement, updating risk ratings, and documenting every decision.

Does this apply to buyers’ agents as well as listing agents?

Yes. AUSTRAC’s designated services capture anyone arranging a property transaction on a client’s behalf, including buyers’ agents and developers selling directly.

Do I need to verify overseas buyers differently?

Yes. Overseas buyers typically trigger Enhanced Due Diligence (EDD) rather than standard checks: our risk engine weights overseas nationals and non-residents more heavily, reflecting the higher risk generally associated with cross-border transactions. That said, as a reporting entity, your role isn’t to investigate or enforce. It’s to apply the right level of due diligence and report to AUSTRAC when genuine suspicion arises.

What happens if a sale falls through after CDD is complete?

Retain the records regardless; the 7-year retention requirement applies to the due diligence performed, not only completed sales.