Tijana Misur
The recent AML Timeline: Meeting AUSTRAC Requirements webinar brought together real estate professionals from across the industry to better understand what the upcoming AML/CTF reforms will mean in practice. Led by Tijana Misur, Head of Audit and Training at AMLHUB, the session unpacked why the real estate sector is being brought into the AML regime, the risks property presents in the global fight against money laundering, and the practical steps agencies can start taking now to prepare. Tijana walked attendees through the fundamentals of AML compliance, including the role of the AML Compliance Officer (AMLCO), the importance of building a robust compliance programme, and how agencies can begin embedding a culture of compliance across their businesses.
A key theme throughout the session was that while AML can feel complex at first, it ultimately becomes part of normal business operations over time. As Tijana explained, strong compliance processes not only help meet regulatory obligations but can also provide valuable insights into clients and transactions. The session also explored different approaches agencies can take to manage AML requirements — from internal processes to hybrid or outsourced models — and highlighted the importance of having the right tools, training, and systems in place ahead of implementation.
One of the most engaging parts of the webinar came during the live Q&A session, where attendees submitted an overwhelming number of thoughtful and practical questions. From compliance officer responsibilities and outsourcing options, to costs, audits, and how AML will impact day-to-day real estate operations, the discussion highlighted just how much interest there is across the industry in preparing early and getting AML right. Below we’ve summarised some of the key questions raised by attendees, along with Tijana’s insights and guidance.
Live Q&A session unpacked;
Do AML Compliance Officers need to be licensed real estate agents?
No. An AML Compliance Officer (AMLCO) does not need to be licensed in real estate. However, it is beneficial if they understand how the real estate business operates. The AMLCO should be a fit and proper person, an Australian resident, and have the authority and support of senior management to perform their role effectively. This could include an owner, director, or another senior staff member. For full AMLCO requirements refer to AUSTRAC's guidance.
Is there a requirement to appoint a senior manager?
There is no requirement to formally appoint a senior manager, but every organisation will have individuals who are considered senior management. These typically include owners, directors, or executives (such as CEOs or CFOs) who the AMLCO reports to and who ultimately hold accountability for compliance.
How much time does an AMLCO typically spend if compliance is outsourced?
If Customer Due Diligence (CDD) is outsourced, the AMLCO will typically spend approximately 4–7 hours per week managing AML-related tasks.
There will be periods requiring additional time, such as independent audits, compliance reviews and assurance activities. Without outsourcing, managing AML for 100+ transactions per month could become a full-time role.
What does AML compliance typically cost?
Costs for AML compliance depend on several factors, including the number of annual transactions and the level of support required.
AMLHUB operates on a monthly subscription model, helping spread costs over time rather than requiring a large upfront payment. Many agencies find the cost lower than expected.
Can AML compliance be outsourced?
Yes, mostly. Certain aspects of compliance can be outsourced, including Customer Due Diligence (CDD) and assurance reviews. However, the legal responsibility for compliance cannot be outsourced. AMLHUB offers a fully or partially outsourced service tailored for your business.
Did many people leave the real estate industry in New Zealand after AML laws were introduced?
While many people initially expected AML regulations to significantly disrupt the industry, this did not result in widespread exits from real estate. Although the first few months were challenging, the AML regime has since become part of normal business operations, much like other regulatory requirements within the industry.
Can small businesses use the AUSTRAC starter kits for their risk assessments and procedures?
Short answer, yes. The AUSTRAC starter kits are designed primarily for smaller businesses. However, they are quite extensive and can be difficult to navigate without compliance experience. While they provide technically correct guidance, many businesses benefit from training or support to implement them effectively.
If an agency is licensed but not actively providing designated services, do they still need to register with AUSTRAC?
An agency only becomes a reporting entity if it provides a designated service, such as selling property or acting as a buyer’s agent. If no designated services are being provided, registration with AUSTRAC is not required. However, agencies should ensure they clearly understand when they begin offering designated services to avoid compliance issues.
How can sole traders manage AML requirements given the workload and costs?
AML compliance can be challenging for sole traders because the same legislation applies to both large firms and very small businesses. AUSTRAC has provided some support through starter kits and training resources, but the process can still feel complex. AMLHUB has tailored solutions to assist smaller businesses in a cost-effective way. Get in touch for a proposal.
Is audit support included and can assistance be provided for audit preparation?
Independent audits must remain fully independent, meaning the same provider cannot both build the compliance framework and conduct the audit. However, organisations can receive support preparing for an audit, such as reviewing documentation, identifying potential gaps, and ensuring processes are in place before the formal audit takes place.
How does AML apply to contractors working under an agency?
Generally, yes, contractors working under an agency are still covered under the agency’s AML compliance program. The agency remains the reporting entity responsible for ensuring all staff and contractors follow the required AML procedures.
Is the cost of an external auditor included in AML services?
No. AML legislation requires independent audits, meaning the same provider cannot both build the compliance program and conduct the audit. External audits are therefore separate from AML service subscriptions.
Costs vary but can typically range around $3,000 - $50,000+ depending on the size and complexity of the business.
Are agencies able to pass AML compliance costs on to clients?
Some agencies may choose to incorporate compliance costs into their broader service or transaction fees, but this depends on the agency’s business model and regulatory considerations.
Do hybrid or DIY models provide the required compliance documentation?
Yes. Hybrid or DIY models typically provide the necessary compliance documentation, such as:
- Risk assessments
- Compliance programs which document your policies, procedures, and controls.
Is staff vetting required?
Yes. AML programs require organisations to ensure that staff involved in AML processes are suitable and appropriately vetted. This helps reduce internal risks and supports the integrity of the compliance program.
How do agencies register with AUSTRAC?
AMLHUB will be running a session on this. Please check our website or follow our LinkedIn Page for updates. Initial indicative dates are late March, registrations open 31 March 2026.
What happens if someone registers as a bidder at auction shortly before the auction?
Agencies will need processes to ensure Customer Due Diligence (CDD) requirements are completed before a transaction progresses. This will include not only identifying their client (typically the vendor) but also the ultimate buyer. Some flexibility is built into the legislation with the inclusion of delayed CDD. This is a technical area and will be considered in specialised CDD training and in your AML Compliance Program.
Have real estate agencies built internal compliance teams over time?
Some larger agencies have developed internal compliance teams, while many smaller agencies choose to outsource compliance or use hybrid models to manage requirements more efficiently. It all comes down to size and resources.
How does AMLHUB’s technology compare to competitors claiming advanced automation?
AMLHUB focuses on combining technology with expert compliance support to ensure agencies meet their regulatory obligations effectively. The goal is not just automation but ensuring compliance programs are implemented correctly and maintained over time.
Contact AMLHUB today to book a demo or discuss how we can help your organisation transition seamlessly into the new regime.
