The smart agent’s guide to AML/CTF (the package) is a practical training package designed to help frontline real estate professionals understand and apply their anti-money laundering and counter-terrorism financing (AML/CTF) obligations in day-to-day real estate activities. It’s been designed in a train-the-trainer format, so you can use it to facilitate training for your staff.
What the package is
The package focuses on real-world application to help frontline real estate professionals:
- understand their role
- recognise money laundering, terrorism financing and proliferation financing risks (we refer to these as ML/TF risks) and indicators
- complete customer due diligence (CDD)
- manage client conversations
- know when and how to escalate matters.
The package is designed to:
- build confidence
- support consistent decision-making concepts in the industry
- help AML/CTF become a part of typical professional practice in real estate.
This package is educational in nature and isn’t exhaustive. It should be used in conjunction with our guidance. While this package can be used as part of your AML/CTF training for your personnel, it doesn’t fulfil your business’s obligation to provide training specific to your business and its ML/TF risks. You remain responsible for complying with your AML/CTF obligations.
Who the package is for
Frontline real estate professionals that are regulated by us, including:
- residential and commercial real estate agents
- buyer's agents
- sales agents
- property professionals involved in customer onboarding, CDD and client interactions
- principals and agency leaders who want to understand the training delivered to their frontline teams.
How it helps
The package helps frontline real estate professionals:
- understand their AML/CTF obligations
- recognise sector-specific ML/TF risks and indicators
- conduct and support CDD
- manage AML/CTF-related client conversations with confidence
- understand escalation requirements and reporting pathways.
Who the package isn’t for
The package doesn’t provide comprehensive guidance on developing, implementing or maintaining a real estate agency’s AML/CTF program.
To learn more about understanding your obligations and building and maintaining an AML/CTF program go to:
- Resources to help you understand your AML/CTF obligations
- Resources to help you build an AML/CTF program
- Resources to help you implement risk controls in your program
- Resources to help you maintain your AML/CTF program.
You can also use our real estate program starter kit.
If you’re an AML/CTF compliance officer, you can learn more about your responsibilities and download resources.
How to use the package
The package is designed to be delivered by trainers in a facilitated workshop setting. Real estate professionals can also use resources from the package to reinforce learning within their teams.
The package is structured across 3 modules as a progressive learning journey:
- why AML/CTF matters
- CDD, risks and obligations
- AML/CTF in practice.
Each module combines explanations, interactive activities, scenarios, discussions and reflections to build knowledge, practical skills and confidence.
Trainers should deliver the modules in sequence, as each module builds on the knowledge and skills developed in the previous one. Trainers can then use the supporting tools, guides, scenarios and conversation resources to reinforce learning and help embed AML/CTF practices into everyday practice.
What’s included in the package
The key components of the package include the training slide deck, which contains 3 practical learning modules:
- Why AML/CTF matters: builds understanding of ML/TF risks in the real estate sector and addresses common misconceptions.
- What to look for, what to do and your obligations: covers AML/CTF obligations, customer due diligence, risk indicators and practical decision making.
- AML/CTF in practice: focuses on client conversations, managing objections, avoiding tipping off and escalation processes.
Trainers and facilitators
The package includes an instructor guide and facilitation manual for trainers and facilitators, which contains:
- speaker notes and delivery guidance
- suggested timing and session plans
- adult learning and facilitation tips.
It also includes resources to support consistent delivery for trainers and facilitators, including:
- interactive activities and role plays
- participant exercises and discussion prompts
- supporting training materials and worksheets.
Together, these resources provide a learning experience focused on helping frontline real estate professionals apply AML/CTF requirements in practice.
Self-paced learning AML/CTF videos
While the package is designed to support trainer- or facilitator-led delivery, we also have videos to help all reporting entities understand their AML/CTF obligations. These videos are self-paced for use by frontline real estate professionals.
The videos cover the same content, learning outcomes, practical activities and real-world scenarios as the workshop-based training, using industry presenters as on-screen guides.
This allows frontline real estate professionals to engage with the material at their own pace and revisit key concepts when needed.
To access the videos, visit our e-learning page.
Downloads
Below are links to the documents you need for the training package.
| Document name | Link |
|---|---|
| Instructor guide and facilitation manual | REI Education - The Smart Agent's Guide to AMLCTF - Instructor Guide & Facilitation Manual (PDF 1.01 MB) |
| Participant pre and post questionnaires | |
| Presentation slides | REI Education - The Smart Agent's Guide to AMLCTF Slide Deck (PPTX 145.61 MB) |
| Module 1 activity handouts |
REI Education - Module 1 Activity Guess Who Option 1 (PDF, 459.84 KB) REI Education - Module 1 Activity Guess Who Option 2 (PDF, 780.74 KB) REI Education - Module 1 Activity Guess Who Option 3 (PDF, 685.34 KB) |
| Module 2 activity handouts |
REI Education - Module 2 Activity worksheet (PDF, 1.68 MB) REI Education - Module 2 Quick Reference Guide MLTF Risks and Indicators (PDF, 578.07 KB) |
| Module 3 activity handouts |
REI Education - Module 3 Client FAQ Guide (PDF, (629.96 KB) REI Education - Module 3 Role play activity client conversations in practice (PDF, 552.93 KB) |
Disclaimer
This practical training package is designed to help the real estate sector better understand and apply their AML/CTF obligations when they provide designated services. This package represents AUSTRAC’s interpretation and application of the law as at the time of publication. Any departure from it may result in the package no longer reflecting AUSTRAC’s position. It is not intended to represent an interpretation and application of the law in all circumstances. It might include generalisations about the application of the law. Some provisions of the law referred to have exceptions or important qualifications. Your particular circumstances must be taken into account when determining how the law applies to you.
This package is not intended to be exhaustive and does not fulfil your business’s obligation to provide AML/CTF training to your personnel. It is not a substitute for legal advice about any reporting entity’s AML/CTF compliance obligations. Australian courts are ultimately responsible for interpreting AML/CTF legislation and determining if any provisions of these laws are contravened. You may wish to seek independent advice to ensure you understand your obligations.
Copyright in all material produced by AUSTRAC is owned by the Commonwealth of Australia.
This guidance sets out how we interpret certain Australian legislation, along with associated Rules and regulations. Australian courts are ultimately responsible for interpreting these laws and determining if any provisions of these laws are contravened.
The examples and scenarios in this guidance are meant to help explain our interpretation of these laws. They’re not exhaustive or meant to cover every possible scenario.
This guidance provides general information and isn't a substitute for legal advice. This guidance avoids legal language wherever possible and it might include generalisations about the application of the law. Some provisions of the law referred to have exceptions or important qualifications. In most cases your particular circumstances must be taken into account when determining how the law applies to you.