The AML/CTF Tranche 2 starting-point checklist
Seven questions, each cited to AUSTRAC's own published guidance — a way to sanity-check your position, not a substitute for AUSTRAC's real estate program starter kit or your AML/CTF adviser.
Not legal advice
This is general information about AUSTRAC obligations, drawn from AUSTRAC's published guidance as at 27 August 2026 — not legal advice, and not a complete statement of your obligations. Confirm how they apply to your business with your AML/CTF compliance officer or a qualified adviser before relying on it.
Are you enrolled with AUSTRAC as a reporting entity?
AUSTRAC — Real estate designated services ↗Can you show initial CDD was completed before you began providing a designated service to this customer — not after?
AUSTRAC — Initial customer due diligence (Reform) ↗Do you know which retention clock applies to which record — CDD records run 7 years from the end of the business relationship, transaction records 7 years from the transaction date?
AUSTRAC — Record keeping overview ↗If a screening result raised a concern today, do you know your clock — 3 business days to lodge an SMR, 24 hours if it involves suspected terrorism financing?
AUSTRAC — Suspicious matter reports ↗Is your identity verification based on documentation or electronic data you could describe as reliable and independent, if AUSTRAC asked you to explain the method?
AUSTRAC — Customer identification and verification ↗Do you have a written AML/CTF program — customised to how your agency actually operates — rather than a process that lives in one person's head?
AUSTRAC — Real estate program starter kit ↗If your CDD record could have been quietly edited after the fact with no way to tell, would that hold up if it were ever tested?
Practical question — not an AUSTRAC-specified test
This is a starting point, not the full list — AUSTRAC's real estate program starter kit is the primary resource for building your actual program.
Sources (checked against austrac.gov.au, 27 August 2026)