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Where agencies actually stand, 41 days before 1 July 2026

Hundreds of agents attended AML/CTF readiness roadshows across NSW, Victoria, Queensland, and the ACT. They asked good questions. Most still haven't finished the work. Here's where the gap is.

By AML Simple Team

Hundreds of real estate agents attended AML/CTF readiness roadshows across NSW, Victoria, Queensland, and the ACT between March and April 2026. They asked good questions. They wanted to understand how to manage compliance efficiently.

That's encouraging.

But attending a roadshow and being compliant are two different things. With 41 days until 1 July 2026, most agencies have a clearer picture of what's required — and a shorter runway than they think.

The fastest way to close the gap

One option for agencies that haven't completed their setup is AML Simple.

  1. Sign up — around 2 minutes. Enter your ABN and AML Simple pulls your registered business details automatically. Your organisation profile is pre-filled.
  2. AUSTRAC Readiness Check (/check) — around 5 minutes. Answers the questions your agency needs to address before 1 July 2026 and shows exactly where you stand.
  3. AML/CTF Program Generator (/program/generate) — around 15 minutes. The wizard asks the right questions about your agency and generates your AML/CTF program document, consistent with AUSTRAC's Program Starter Kit structure.

You have a documented starting point for your program, a record-keeping log has begun, and you have a clearer picture of remaining steps.

Want to understand what's behind each step? Here's the full picture.

What "attending a roadshow" means

The Securexchange "Ready-Set-Go AML/CTF Roadshow" reached agents across four states. Their post-event report described agents who "asked questions, sought clarity, and focused on managing compliance efficiently and accurately."

That's the market at its best. Agencies taking the obligation seriously, showing up, doing the work to understand what's coming.

But readiness roadshows cover the what, not the done. An agent who can explain CDD requirements hasn't necessarily completed them.

What done actually looks like

Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), as amended by the 2024 reforms, reporting entities are required to have the following in place from 1 July 2026:

  • Enrolled with AUSTRAC
  • A documented AML/CTF program covering risk assessment, policies, CDD procedures, training, and record-keeping
  • A compliance officer appointed at senior management level
  • Staff trained on AML/CTF risk awareness before performing compliance-relevant duties
  • Active CDD processes for new clients from 1 July

The compliance officer must notify AUSTRAC of their appointment by 29 July 2026.

Each of these is a separate step. Knowing they're required is different from having them done.

Where the gap usually is

Based on the questions agents ask most often, the breakdown tends to follow a pattern.

Enrolment: Most agencies in active preparation have enrolled, or know they need to. AUSTRAC's online enrolment portal opened on 31 March 2026. The deadline to complete enrolment is 29 July 2026.

The AML/CTF program: This is where most agencies are still working. A program isn't a single document — it's a set of policies and procedures covering how your agency identifies risk, verifies clients, trains staff, and handles reporting. The AUSTRAC Real Estate Program Starter Kit provides the template structure. Filling it in requires answers specific to your agency: your services, your client types, your staff, your risk profile.

CDD process: Many agencies understand that they need to verify clients. Fewer have a working process in place — what questions to ask, what documents to collect, how to record the outcome, what to do for high-risk clients.

Staff training: Often left for last. Under the Act, staff are required to complete AML/CTF risk awareness training before performing AML-relevant duties. With 41 days to go, "we'll do training before July" is still achievable — but the window is narrowing.

Why the last six weeks matter more than the first six months

The agencies that started preparation in January had the luxury of time. They could research, get quotes, compare tools, ask lawyers.

The agencies working now don't have that luxury. They need to make decisions and execute.

The question isn't which solution is theoretically best. It's which steps you can actually complete before 1 July.

What AML Simple handles for you

If you'd rather do it yourself, here's what each step involves:

Enrolment means creating an account in AUSTRAC Online, registering as a reporting entity, and providing details about your business and designated services. Allow 30-60 minutes for a first-time enrolment.

The AML/CTF program means working through AUSTRAC's Real Estate Program Starter Kit — a set of templates covering risk assessment, CDD procedures, governance, training, and record-keeping. For a small agency with a single designated service, the Starter Kit is designed for businesses with up to 15 staff. Working through it without a tool takes 4-8 hours.

CDD procedures means defining how you'll verify client identity for each transaction — what documents you collect, how you assess risk, what your records contain. For standard CDD, AUSTRAC guidance describes acceptable verification approaches including government-issued photo ID verified against the DVS (Document Verification Service, operated by the Department of Home Affairs).

Training means delivering AML/CTF risk awareness training to any staff who will be involved in client-facing AML compliance activities. Training can be formal (a course) or informal (documented internal sessions) — the obligation is that it happens and is recorded.

AML Simple handles the program structure, client screening, record-keeping, and training through the platform. The decisions — which clients, which risk ratings, which reports — remain yours.

41 days is enough time

If you start this week, you can be compliant by 1 July.

The agencies that attended roadshows already have the knowledge. What's left is the setup.

Penalties under the Act for serious or repeated contraventions can reach up to $33 million per contravention for body corporates and up to $6.6 million per contravention for individuals. These figures are the upper end; AUSTRAC has described a "supportive but firm" approach to businesses making good-faith efforts.

Good-faith effort means actually having the program in place. Not having attended a seminar about it.

Start your AML program at amlsimple.com — takes around 15 minutes for the program generator.

For the full breakdown of every Tranche 2 obligation, deadlines, and penalties, read the AUSTRAC Tranche 2 complete guide for real estate agencies.

This post describes regulatory obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), as amended, and AUSTRAC guidance as of May 2026. AML Simple is a compliance workflow tool. It does not provide legal advice. If you need advice on your specific obligations, consult a qualified AML compliance professional.

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