AML/CTF Compliance Officer for Real Estate
What real estate businesses need to know about appointing an AML/CTF Compliance Officer, eligibility, records and current AUSTRAC notification timing.
Every reporting entity needs an eligible AML/CTF Compliance Officer. For a smaller real-estate business, that person may be an owner, director or someone responsible for broader risks or operations. The appointment still needs to meet AUSTRAC's eligibility, authority, record and notification requirements.
This guide is general information, not legal advice. Assess the role against your business and seek advice where your circumstances are unclear.
What does the AML/CTF Compliance Officer do?
AUSTRAC says the officer communicates with it on the business's behalf and oversees and coordinates day-to-day compliance with AML/CTF obligations. The role includes:
- overseeing the effective operation of AML/CTF policies
- having sufficient authority, independence and access to resources and expertise to perform the role effectively
- reporting to the governing body at least once every 12 months on AML/CTF compliance.
The officer does not have to perform every compliance task personally. They must oversee and coordinate the work, make sure significant issues are visible to the governing body, and help the business maintain an effective response as its risks and operations change.
Who can be eligible?
AUSTRAC says an AML/CTF Compliance Officer must meet eligibility requirements, including being:
- employed or engaged by the business at management level
- a resident of Australia where the business provides designated services at or through a permanent establishment in Australia
- a fit and proper person.
For a smaller business, AUSTRAC says a person at management level may be the business owner, a director, or a person responsible for broader risks or operations. Management level is about authority in the business, not whether the person has direct reports.
The officer does not need to be an AML/CTF expert. AUSTRAC says a small business should appoint a person with the relevant capability and judgement who can learn the business's ML/TF risks and develop further skills through training and experience. Eligibility remains the reporting entity's assessment; it should not be assumed from a job title alone.
What should the business consider and record?
Before appointing an officer, AUSTRAC says the business must determine whether the person is fit and proper. That assessment includes competence, skills, knowledge, diligence, expertise and judgement, as well as character, integrity, serious-offence history, regulatory findings, insolvency and material conflicts of interest.
Keep records showing:
- who was appointed and when they acted in the role
- how they met the eligibility requirements
- what the business considered, including any checks or reassessments
- the resources, authority and access provided to support the role.
AUSTRAC also expects the business to reassess the officer periodically. If the officer leaves or becomes ineligible, the business must appoint a new person and advise AUSTRAC of the change.
When must the officer be appointed and notified?
AUSTRAC says a business must appoint an AML/CTF Compliance Officer within 28 days of providing designated services and notify AUSTRAC within 14 days of the appointment using the enrolment form in AUSTRAC Online.
For newly regulated entities, the notification deadline is the later of:
- 29 July 2026, or
- 14 days after enrolling.
For example, AUSTRAC says a business that enrols on 29 July has until 12 August 2026 to notify it of the appointment. Enrolment and notification are separate actions, so keep evidence of both.
What should a principal do next?
Use this short sequence to organise the work:
| Step | Action | Evidence to keep |
|---|---|---|
| 1 | Identify a proposed officer with the right management authority. | Role decision and authority record. |
| 2 | Complete and document the fit-and-proper assessment. | Checks, considerations and reassessment plan. |
| 3 | Give the officer access to information, people and resources needed for the role. | Governance and resourcing record. |
| 4 | Appoint and notify the officer on time. | Appointment and AUSTRAC Online notification evidence. |
| 5 | Plan the written annual report to the governing body. | Report schedule and retained report. |
AUSTRAC's approach is risk-based. It expects newly regulated businesses to be enrolled, have an AML/CTF program and officer, train staff and be ready to report suspicious matters. It also expects effort, not perfection, as businesses continue embedding the reforms during FY26/27.
Where AMLHive fits
AMLHive helps real-estate teams organise workflow, tasks, evidence and review records across screening, KYC/KYB, CDD, AML/CTF program documentation, training and reporting templates.
It does not provide legal advice or determine whether a person is eligible to be a Compliance Officer. It does not automatically lodge a report with AUSTRAC. The reporting entity remains responsible for its decisions and for submitting reports through AUSTRAC Online.
Related AMLHive guides
Sources
- AUSTRAC - AML/CTF compliance officer (accessed 10 July 2026)
- AUSTRAC - Enrol now and meet your obligations (accessed 10 July 2026)
- AUSTRAC - Update to regulator statement of expectations (accessed 10 July 2026)
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.