Expert compliance solutions.
Guiding Agents to regulatory success.
Drafted by lawyers - Designed for real estate.
Expert compliance solutions.
Guiding Agents to regulatory success.
Drafted by lawyers - Designed for real estate.
Our AML/CTF Program
Independent Risk Assessment
- Identify clients and transactions that present higher money laundering or terrorism financing risk
- Assess and measure the level of risk across your business operations
- Develop and implement an AML/CTF program tailored to effectively manage and mitigate these risks
Draft AML/CTF Program
- Establish clear internal policies to identify and verify clients in accordance with AML/CTF obligations
- Implement documented procedures for assessing and managing higher-risk clients and transactions
- Define processes for ongoing monitoring, reporting, and record-keeping to ensure continued compliance
- Regularly review and update your AML/CTF program to reflect changes in business operations or regulatory requirements
Monitoring & Audit
- Establish a comprehensive transaction monitoring program
- Understand and detect patterns linked to criminal network funding methods
- Identify potential structuring or suspicious activity through ongoing monitoring
- Implement automated systems and controls to seamlessly track and flag unusual transactions
- Conduct independent audits to ensure adherence to AML/CTF policies, operational integrity, and proper data retention
Reporting Policy
- Detect and assess transactions or behaviors that may indicate suspicious activity
- Apply your Enhanced Due Diligence (EDD) program to verify and investigate potential risks
- Lodge a Suspicious Matter Report (SMR) with AUSTRAC when required
Retention of Data
- Secure Data Collection: Ensure all Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) information is collected securely, minimizing exposure to unauthorized access
- Safe Storage Practices: Store all client data, reports, and records in secure systems (encrypted, password-protected, or cloud solutions compliant with privacy and cybersecurity standards)
- Retention Period: Retain all CDD and EDD records, as well as transaction and suspicious matter reports, for 7 years in line with AUSTRAC requirements
- Access Controls: Limit access to sensitive information to authorized personnel only; maintain logs to track access and modifications
- Cyber Protection Measures: Implement firewalls, antivirus software, regular system updates, and data encryption to prevent breaches or cyber-attacks.
- Data Disposal: Ensure secure deletion or destruction of records once the retention period expires, following best-practice data disposal procedures.
Training
- Documented Training: Provide formal training to ensure all staff fully understand current AML/CTF laws and obligations
- Onboarding New Staff: Include AML/CTF program training as part of the induction process, highlighting operational procedures and the designated compliance officer.
- Human Resources Integration: Update employment contracts and job descriptions to reflect AML/CTF responsibilities and compliance obligations.
- Roles & Responsibilities: Clearly define reporting lines, staff responsibilities, and directors’ obligations in relation to AML/CTF compliance.
- Ongoing Education: Conduct regular refresher training to ensure staff stay informed of legislative changes and internal procedure updates
Our Real Estate AML Compliance Officers
Agencies have told us their biggest pinch points managing AML internally include:
- "AML is taking us too long"
- "More complexity reviewing trust deeds, SMSF'sand identifying UBO's"
- "Search provider questions are confusing our clients, more finance focused not real estate"
Does this resonate? Call us today, we can help.