29 July Has Passed: Your Next AML/CTF Steps
29 July has passed. Here is a practical next-step checklist for Australian real estate agencies: enrolment, CDD, reporting and records.
29 July Has Passed: Your Next AML/CTF Steps
The 29 July 2026 AUSTRAC enrolment date has passed for newly regulated businesses that started providing a designated service on 1 July. For a real-estate agency, the useful question now is not whether the countdown is over. It is whether the practical pieces of the AML/CTF program are working in the ordinary flow of a matter.
This is a practical starting point, not legal advice. Your agency remains responsible for its own AML/CTF decisions and obligations.
Start by confirming what happened with enrolment
AUSTRAC says an enrolment application submitted through AUSTRAC Online generates a receipt and an AUSTRAC reference number (AAN). AUSTRAC may then confirm the enrolment or ask for more information. Keep that evidence with the person who owns the agency's compliance work, rather than relying on a remembered submission or a shared inbox.
If you have not applied, or your application status is unclear, do not assume what the outcome will be. Check the current guidance in AUSTRAC Online and contact AUSTRAC to resolve your own position. The date passing does not make the operating obligations disappear.
Make the compliance officer role real
The AML/CTF compliance officer should be identifiable inside the business, have enough authority and resources to do the job, and be able to take issues to senior management when needed. AUSTRAC's transitional rules set the notification date for newly regulated businesses as the later of 29 July 2026 or 14 days after enrolment. That later-of rule matters: a business that enrolled on 29 July, for example, has a different notification date from one that enrolled earlier.
The role is more than a name in a policy. Give the officer a clear owner for questions from staff, an escalation path, access to the agency's AML/CTF program and a record of decisions made.
For a plain-English explanation of the role, see AML/CTF Compliance Officer for Real Estate.
Turn the program into everyday workflow
From 1 July 2026, newly regulated real-estate businesses have obligations around an AML/CTF program, customer due diligence (CDD), suspicious-matter reporting and record keeping. A program that exists only as a document is difficult for staff to use when a real client matter becomes unusual or complex.
This week, walk through a typical sale, purchase or leasing matter and make sure the team can answer these questions:
- What tells us that this service is in scope for our agency?
- Who is responsible for collecting and recording customer information?
- How do staff raise a concern, and who decides the next step?
- Where do we retain the evidence and rationale for an escalation or a decision?
- If a reporting obligation arises, who has access to the current AUSTRAC Online process?
Those are operational questions, not a substitute for a risk assessment. But they expose whether your documented process can be followed in practice.
For an overview of designated services and scope, read Real Estate AML/CTF: Are You Covered?. For reporting readiness, see New AUSTRAC SMR Form: Real Estate Readiness.
Do not automatically redo every existing customer file
AUSTRAC's guidance for pre-commencement customers does not require an agency to perform initial CDD for every existing customer simply because the new regime began. It does set out circumstances where initial CDD may be required, including where an obligation to submit a suspicious matter report arises, or where a significant change in the relationship increases money-laundering or terrorism-financing risk to medium or high.
That is why an agency needs a workable way to recognise changes and unusual activity, not just a one-off clean-up exercise. Read the detail in Existing Customers and CDD After 1 July.
A practical first-five-business-days checklist
Use the next few working days to get a small number of basics into a repeatable rhythm:
- Confirm the enrolment receipt, AAN and any AUSTRAC follow-up are held by the right people.
- Confirm the compliance officer appointment and the applicable notification date.
- Brief client-facing staff on the escalation route for unusual activity and record that the briefing occurred.
- Test one representative matter against your CDD, screening, evidence and record-keeping steps.
- Check that any change to business or designated-service details is identified promptly; AUSTRAC says relevant enrolment details must be updated within 14 days after a change.
Then set a cadence for reviewing how the process is working. AUSTRAC's transitional rules also set different first independent-evaluation dates based on an agency's AAN. Once your AAN is confirmed, use the current rule to identify the date that applies to your business and record it in your compliance calendar.
Where AMLHive fits
AMLHive can help an agency organise customer checks, screening outcomes, evidence notes and handover records in one workflow. It does not make AML/CTF decisions for your agency, provide legal advice or lodge a report on your behalf. The agency retains responsibility for its program, decisions and obligations.
The countdown has ended. The useful work now is making a clear, evidence-backed process routine enough that staff can follow it when a real matter needs attention.
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Disclaimer:This article is general information only and is not legal, financial or compliance advice. Always consider your agency's specific circumstances and seek professional advice where needed.