As AUSTRAC moves to bring real estate agencies under the scope of Anti-Money Laundering (AML) laws, a growing number of business owners are wondering: Can I just do this myself? It’s a fair question — but one that experts urge the industry to approach with caution.
Although AUSTRAC has promised forthcoming guidance for reporting entities, some real estate agencies are waiting for this guidance and plan to implement AML programs themselves.
But what seems like a cost-saving measure at first can quickly become a time-consuming and frustrating task — with significant legal risk if done incorrectly.
Understanding the DIY Option
According to the legislation, a real estate agency can technically read the AML/CTF Act, study AUSTRAC’s materials, and attempt to build a compliance program in-house.
But Richard Manthel, a director with extensive AML experience, warns that this is no small undertaking.
“Even with my 10 years’ experience in AML, I would never try to create and implement my own program.” Manthel says.
“The time it would take me, and the frustrations in understanding the legislation and guidance, are the main reasons. I would always leverage the expertise available — both for document creation and the software tools to implement the program effectively.”
AUSTRAC Sets the Rules — But Not the Implementation
AUSTRAC’s upcoming and promised guidance pack will provide essential information.
But it’s important to understand the role of the regulator: to explain the obligations, not to deliver an operational compliance solution.
“AUSTRAC’s ‘Develop your AML/CTF Program’ framework outlines what every reporting entity must have in place — and it’s helpful,” Manthel says.
“But no downloadable pack, template, or checklist can deliver full compliance on its own.”
This point is echoed by Kathrine Andersen, VP of Sales at AMLHUB, who has worked closely with real estate professionals navigating similar reforms in New Zealand.
We’re constantly monitoring AUSTRAC’s announcements and updates, and we see firsthand just how detailed and complex these requirements can be,” Andersen explains.
“Even with clear guidance from the regulator, real estate businesses can’t be expected to manage all of this on their own. In New Zealand, when similar AML legislation rolled out, compliance officers were overwhelmed by the documentation and the ongoing workload.
The risk-based legislation is nuanced, and while it’s possible to build in-house expertise, it takes time and effort. Having an experienced partner to support your efforts is essential.”
What the Real Estate Industry Can Learn from New Zealand
New Zealand’s rollout of similar AML legislation revealed a key lesson: even with templates and guidance, implementation is a full-time operational project.
Compliance doesn’t end with document preparation — it involves continual updates, staff training, reporting obligations, and audits.
Agencies that underestimated the ongoing workload faced penalties, inefficiencies, or the need to retrofit their approach under pressure.
Many found that partnering with a compliance specialist allowed them to meet legal obligations without losing focus on day-to-day business operations.
Why AMLHUB Exists
This is where providers like AMLHUB come in.
The company has developed an end-to-end AML compliance platform tailored for real estate agencies, combining AML expertise, technology, and training services.
“AMLHUB’s role is to create AML documents, train you in AML obligations and AUSTRAC’s requirements, and provide a proven AML platform and apps — and then actually assist you put all into practice,” Andersen says.
“Our platform turns guidance into structured, practical compliance. It helps agencies meet their obligations without needing to be an AML specialist.”
With AUSTRAC’s supervision now extending to real estate, the compliance bar is rising.
Agencies need to start planning, and act smartly.
Final Word: Be Prepared, Not Reactive
The message from industry experts is clear: DIY compliance is an option, but without experience it is a time consuming and frustrating process and the risks far outweigh the benefits.
The smarter strategy is to take AUSTRAC’s guidance seriously — and engage proven AML partners who can help implement it correctly.
AUSTRAC sets the rules.
AMLHUB helps you meet them.
For more information about AML and how to prepare, visit amlhub.com.au.
