AUSTRAC Real Estate Starter Kit: What Changed?

AUSTRAC's real estate program starter kit is now at release version 1.1.

Release version: 1.1 | Release date: 3 June 2026

If your agency used the kit to build an AML/CTF program, this is a review trigger: compare the current release with your working documents, update the affected processes, and retire superseded copies.

The update covers several workflow areas, including counterparty due diligence, beneficial ownership, risk assessment, reporting and program maintenance. It does not mean every agency can use the starter kit unchanged. Your program still needs to reflect your business, services, customers and risks.

This is general information only, not a determination about your agency or a substitute for legal advice.

What changed in v1.1

AUSTRAC identifies the following themes in its real estate starter kit release:

• Delayed CDD timeframes for counterparties: the release changes the documented delayed customer due diligence timeframes from 15 days to 28 days after exchange of contracts or 3 days before settlement.
• Beneficial ownership processes: the affected forms and processes were streamlined to clarify when checks can stop for certain customer types under new deemed-compliance measures.
• Annual compliance reporting: the reporting timeframe moved from a calendar-year basis to a financial-year basis.
• Uncooperative counterparties: the program material now includes the need to record the steps taken when a counterparty does not cooperate and to report suspicious activity to AUSTRAC where the applicable obligation arises.
• Initial risk assessment: risk indicators for unusual or criminal behaviour are clarified as relevant during initial customer onboarding, not only later monitoring.
• Risk information: the kit includes updates from AUSTRAC's 2026 national risk assessment work, including emerging technology risks.
• Program administration: enrolment material and the section about the first independent evaluation were updated, including additional flexibility around the first evaluation timing.

The release page is the source of truth for the full change register. The practical point is to review the affected documents as a package rather than updating one form in isolation.

Who should review their starter kit

The starter kit is intended for small real estate and buyer's agencies that meet AUSTRAC's suitability characteristics. Those characteristics include providing one relevant designated service, having 15 or fewer personnel, mainly dealing with Australian-resident individual customers, not regularly dealing with high-risk customers, not brokering overseas property, and not providing a fully remote self-service designated service.

When the starter kit may not fit

The starter kit is not designed to be used as-is. If your agency does not meet all of the suitability characteristics, AUSTRAC says you must assess whether the kit is appropriate and identify the changes needed. The program must reflect the size, nature and complexity of the business and the risks it faces.

That matters if your agency provides other designated services, handles more complex customer types, works with overseas property, is part of a larger reporting group, or has a business model that creates different risks. You may still adapt useful parts of the starter kit, but you should not treat the package as a complete answer for a different operating model.

A practical review sequence

Use the following sequence to turn the release into an owned review rather than a file-download exercise.

1. Record the version you started from

List the starter-kit documents your agency customised, the version or retrieval date recorded on each, and where the working copy is stored. Check whether staff are still using a superseded form or process from a shared drive, template library or printed folder.

2. Map each v1.1 change to your workflow

Review the risk assessment, policy document, process document and forms together. Ask where your agency handles counterparty CDD timing, beneficial ownership, onboarding risk indicators, uncooperative counterparties, suspicious-activity escalation, annual reporting and independent evaluation planning.

The question is not simply whether a paragraph changed. It is whether the change affects a responsibility, a decision point, a record, a review date or staff training.

3. Test the practical hand-off

Walk through one ordinary matter and one matter that needs escalation. Confirm that the person handling the file knows what to record, who reviews an exception, where supporting evidence is stored, and how the matter returns to the agency's documented process.

For a customer or transaction that does not fit the starter-kit assumptions, route the question to the person responsible for the agency's AML/CTF program. Do not treat a risk indicator as proof of wrongdoing or as an automatic reporting conclusion.

4. Approve and retire carefully

Record what your agency changed, what it decided did not need changing, who approved the program update and when the next review is due. Once the new working documents are approved, retire superseded versions so staff do not have two competing processes in circulation.

This record is part of maintaining a usable program. It is not a certificate that the agency has met every obligation in every circumstance.

How this connects to the rest of your program

Start with Real Estate AML/CTF: Are You Covered? if you still need to confirm the designated-service question. For existing relationships, see Existing Customers and CDD After 1 July. For escalation signals, read Real Estate AML/CTF Risk Indicators: What to Review and New AUSTRAC SMR Form: Real Estate Readiness.

Where AMLHive fits

AMLHive can support a documented workflow by bringing customer checks, screening outcomes, review handovers and evidence notes into one place. It is a workflow and evidence-support tool, not legal advice or an AUSTRAC approval. It does not decide the agency's obligations, automatically lodge reports or replace the agency's AML/CTF decisions and legal responsibility.

The agency retains its AML/CTF decisions and legal responsibility.

Eligible accounts can start a 14-day free trial. Your Virtual Compliance Officer is a product position, not a claim that AMLHive is a statutory officer or outsourced compliance function.

Sources

• AUSTRAC - Recent updates to the real estate program starter kit (release version 1.1, released 3 June 2026; accessed 24 July 2026)
• AUSTRAC - Real estate program starter kit: Getting started (last updated 10 July 2026; accessed 24 July 2026)
• AUSTRAC - Step 1: Customise your real estate program using the starter kit (last updated 10 July 2026; accessed 24 July 2026)
• AUSTRAC - Step 3: Maintain and review your real estate program (last updated 2 April 2026; accessed 24 July 2026)

Re-check AUSTRAC's current release page before publishing or reusing this article. This is general educational material, not an individual legal, financial or compliance answer.