Your First 90 Days as a Real Estate Compliance Officer

What does an AML compliance officer at a real estate agency actually do?

You own the agency's AML program: the risk assessment, the written procedures, customer due diligence standards, screening decisions, suspicious matter reporting, training and record-keeping. You are the person AUSTRAC expects to be able to explain how the agency identifies and manages money laundering risk in the sales it brokers.

What you do not own is every check. Sales agents run CDD as part of listing. You set the standard, handle the exceptions, and keep the evidence. If everything routes through you personally, you have built a bottleneck, not a program.

Days 1–30: read, map, and refuse to guess

Start with the AUSTRAC guidance for Tranche 2 reporting entities and the agency's own paperwork, if any exists. Then map the business as it actually runs: how many sales a year, what buyer types, which suburbs, what proportion of company, trust and SMSF purchasers, how deposits move.

Resist the urge to write procedures in week one. A program written before you understand the business will describe an agency that does not exist. Your only deliverables this month are a clear picture of the risk and a list of what is missing.

Days 31–60: build the program around real transactions

Now write the risk assessment and program — using your map, not a generic template. Walk three recent sales through your draft process end to end. Where would CDD have happened? Who would have collected what? Where does the record land? Every gap you find on paper is one you will not find mid-transaction.

This is also when you set your escalation rules: what a sales agent handles alone, what comes to you, and what triggers enhanced due diligence. Write those thresholds down. Ambiguity here is where programs quietly fail.

Days 61–90: train the team and run it live

Training is not a slide deck about the Act. It is showing a sales agent exactly what they do at listing, what the customer sees, and what to say when someone asks why. Keep it to the five situations your team will actually meet, and rehearse the awkward ones — the buyer who bristles at ID checks, the trust with no deed handy.

Then run the process on live transactions while you still have slack to fix it. The gap between a program that reads well and one that survives a Saturday auction is only discoverable in production.

The two clocks you can never miss

Two obligations have hard deadlines attached, and they are yours. A suspicious matter report goes to AUSTRAC within 3 business days of forming a suspicion — 24 hours if it relates to terrorism financing. And tipping off the customer is a criminal offence, so your escalation path has to be quiet by design.

Build both into muscle memory now. Decide today how a suspicion reaches you, who drafts the report, and who knows. The middle of a live matter is the wrong time to invent the process.

Don't reserve the drill for suspicious matters either. Threshold transaction reporting for physical currency of A$10,000 or more is rarer in real estate, but rare is exactly why it gets fumbled — decide now who lodges it and within the 10-business-day window, so the first cash-heavy transaction is a procedure and not a scramble.

What to refuse to own

Do not become the agency's outsourced conscience. If a principal wants to skip CDD on a big vendor because the relationship is sensitive, that is not your risk to quietly absorb — put it in writing and escalate. If the role has no allocated hours, no training budget and no authority to pause a transaction, say so in your 90-day report.

The compliance officers who burn out are the ones who let the role become a personal guarantee. The ones who last build a system that works when they are on leave.

Finally, secure the small things that make the role real: a standing slot at the sales meeting, sign-off authority written into procedures, and a direct line to the principal that does not route through the person whose deal you might be pausing. None of that costs money. All of it determines whether the program you spend the next 90 days building actually gets followed on day 91.

End the 90 days with a one-page report to the principal: what exists now, what is still missing, what the recurring workload looks like, and the two or three risks you cannot manage without a decision from them. That document does double duty — it is your work record, and it is the evidence that the agency's leadership was told what it needed to hear, dated and in writing.