Learn what updates we’ve made to the real estate program starter kit (starter kit) and the steps you need to take to keep your program current.
If you customised the starter kit to build your anti-money laundering and counter-terrorism financing (AML/CTF) program, you must review these updates and decide if they should be incorporated into your program.
How we update the starter kit
We update the starter kit when:
- new money laundering, terrorism financing and proliferation financing risks (we refer to these as ML/TF risks) are identified
- existing risks or obligations change
- small businesses in your sector change how they operate.
We use these versions to let you know how substantial changes are:
- Patch version (v1.1.1): small corrections (for example, typos, formatting fixes, minor clarifications).
- Minor version (v1.1, v1.2): additions or meaningful improvements (for example, new sections, expanded guidance).
- Major version (v2.0, v3.0): significant changes affecting meaning, structure or workflows.
Summary of what’s changed in the latest release
Release version: 1.1
Release date: 10 June 2026
Change type: Minor
This release updates multiple documents within the starter kit to reflect:
- revised delayed customer due diligence (CDD) timeframes for counterparties from 15 days to 28 days after exchange of contracts or 3 days prior to settlement
- streamlined beneficial ownership processes to clarify when checks can stop for certain customer types under new CDD measures
- updated annual compliance reporting timeframes from calendar year to financial year
- the new requirement to record the steps taken to do CDD for uncooperative counterparties and report suspicious activity to us
- strengthened risk assessment practices, including to clarify that indicators of unusual or criminal behaviour apply during initial customer onboarding
- included details on how to enrol in AUSTRAC Online, noting enrolment started on 31 March 2026
- provided additional flexibility to complete the first independent evaluation of the AML/CTF program
- updated risk information published as part of the 2026 annual updates to our national risk assessments.
The changes also improve clarity and consistency across:
- customer onboarding
- risk assessment
- reporting processes.
Read the change register for details of the sections updated in each document.
The changes ensure alignment with updated AML/CTF regulatory requirements under the:
- AML/CTF Transitional Rules 2026
- Anti-Money Laundering and Counter-Terrorism Financing (2025 Rules) Amendment Rules 2026.
What you need to do
There are 3 things you need to do with this update:
- Apply this release across all affected documents within the starter kit.
- Ensure onboarding, counterparty due diligence, beneficial ownership, risk assessment and reporting processes reflect the updated requirements.
- Replace or retire superseded document versions to prevent reliance on outdated obligations.
Change register
The following table details the changes in this release.
Change type definitions:
- Added: new information, obligations or process steps.
- Updated: changes to existing obligations or process steps.
- Fixed: correction or clarification with no change to compliance intent.
|
Document |
Section / Step |
Change type |
Change summary |
Reason for update |
|---|---|---|---|---|
| Initial CDD forms – Government body | C1, C2, D3, E1.2 | Updated | Sections have been removed in line with new CDD measures. Page and section ordering have been adjusted accordingly | Removed beneficial ownership checks required for government bodies under new CDD measures |
| Initial CDD forms – Body corporate, partnership or association | C1 | Updated | Ownership terminology amended to clarify when you stop beneficial ownership checks. Additional check step included for new CDD measures | New CDD measures |
| Initial CDD forms – Trust | C1 | Updated | Ownership terminology amended to clarify when you stop beneficial ownership checks. Additional check step included for new CDD measures | New CDD measures |
| Initial CDD forms – All entity types | B1 | Updated | Delayed initial CDD timeframe changed from 15 days to 28 days after exchange of contracts or 3 days prior to initially agreed date of settlement | AML/CTF Rules – delayed CDD timing changes |
| Initial CDD forms – All entity types | B3 | Updated | Delayed initial CDD timeframe changed from 15 days to 28 days | AML/CTF Rules – delayed CDD timing changes |
| Initial CDD forms – Trusts, body corporates, partnerships or unincorporated associations | G4 | Added | New step added to address uncooperative counterparties | AML/CTF Rules – Rules R 6.33(2)(3) |
| Initial CDD forms – Individuals or sole traders, government bodies | F4 | Added |
New step added to address uncooperative counterparties
|
AML/CTF Rules – Rules R 6.33(2)(3)
|
| Request to verify information | Part 4 | Updated | Timeline for second entity to collect and verify has been updated to from 15 days to 28 days after exchange of contracts or 3 days prior to initially agreed date of settlement | AML/CTF Rules – delayed CDD timing changes |
| Process document – Beneficial ownership | Steps 4–6 | Updated | Streamlined process to clarify when checks can stop for certain customer types under new CDD measures | New CDD measures |
| Process document – Beneficial ownership | All steps | Fixed | Formatting updates for step numbering and references | Usability |
| Process document – Annual compliance report | Step 1 | Updated | Reporting reference updated from calendar year to financial year | Alignment with financial reporting cycle |
| Process document – Annual compliance report | Step 2 | Updated | Reporting start date changed from 1 January to 1 July | Alignment with financial reporting cycle |
| Process document – Annual compliance report | Step 4 | Updated | Completion date changed from 31 March to on or before 30 September | Alignment with financial reporting cycle |
| Risk assessment – Designated services | New and emerging technologies | Added | Added new risk information about artificial intelligence from the 2026 national risk assessment updates | Alignment with current AUSTRAC risk information |
| Risk assessment – Common ML/TF methods | Added | Added new risk information about DeFi and offshore VASPs from the 2026 national risk assessment updates | Alignment with current AUSTRAC risk information | |
| Risk assessment – Indicators of unusual or criminal behaviour | Section | Updated | Clarified that indicators of unusual or criminal behaviour apply during initial CDD | Earlier risk identification |
| Risk assessment – Indicators of unusual or criminal behaviour | Introduction and all tables | Updated | Expanded “another party” definition to include counterparties and persons acting on behalf of customers, standardised terminology amongst all tables | Broader risk coverage and consistent language |
| Risk assessment – Indicators of unusual or criminal behaviour | Customer profile table | Added | New indicator under “Adverse information or suspected criminal links” to include where a person is engaged in criminal activity with a prohibited hate group | AML/CTF Rules alignment |
| Risk assessment – Risk assessment sources | Added | Added the 2026 national risk assessment updates as a source for the risk assessment | Alignment with current AUSTRAC risk information | |
| Policy document | CDD section | Updated | Delayed CDD timelines updated in line with new counterparty timeframes | AML/CTF Rules alignment |
| Policy document | 4.1(e) | Updated | New requirement to record and escalate uncooperative counterparties for AML/CTF compliance officer review | AML/CTF Rules R 6.33(2)(3) |
| Policy document | 5.2(2.2) | Updated | Updated name of form used to maintain enrolment details | Alignment with AUSTRAC systems |
| Policy document | 6 | Added | Added section: first independent evaluation | AML/CTF Transitional Rules alignment |
| Process document – AUSTRAC enrolment process | Update AUSTRAC enrolment details | Updated | Updated name of form used to maintain enrolment details | Alignment with AUSTRAC systems |
Version history
The following superseded documents contain tracked changes. They’re available as read-only files. To view all tracked changes, open the Review tab in Microsoft Word and select All Markup from the Display for Review menu.
- Risk assessment – version 1.0 (Word 301.36 KB)
- Policy document – version 1.0 (Word 357.04 KB)
- Process document – version 1.0 (Word 220.53 KB)
- Initial customer due diligence forms – Government body, version 1.0 (Word 252.99 KB)
- Initial customer due diligence forms – Body corporate, partnership or association, version 1.0 (Word 242.86 KB)
- Initial customer due diligence forms – Trust, version 1.0 (Word 277.1 KB)
- Initial customer due diligence forms – Individual or sole trader, version 1.0 (Word 197.97 KB)
- Request to verify information – version 1.0 (Word 83.13 KB)
The program starter kits are intended to be used as a complete package and have been designed for use by those reporting entities who satisfy certain suitability criteria. That suitability criteria is set out in the ‘Getting Started’ web page under the heading “Who the starter kit is for” in each program starter kit. In particular, those newly regulated entities who, from 1 July 2026, are for the first time subject to anti-money laundering and counter-terrorism financing legislation (AML/CTF).
The program starter kits have been designed for the purpose of providing practical guidance to those reporting entities to assist them to build their own AML/CTF programs. The program starter kits represent AUSTRAC’s interpretation and application of the law to the eligible reporting entities only and are not intended to represent an interpretation and application of the law in all circumstances. The program starter kits are not a substitute for legal advice about any reporting entity’s AML/CTF compliance obligations. Australian courts are ultimately responsible for interpreting the AML/CTF legislation and determining if any provision of these laws are contravened.
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.