Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), your AML/CTF policies must set out how you train every person who performs functions relevant to your obligations. That training must cover your money laundering and terrorism financing (ML/TF) risks and your obligations, and it must suit each person’s role. Since Tranche 2 commenced on 1 July 2026, this applies to real estate agencies, buyers agents and property developers that provide designated services. This guide explains what the law asks your policies to say about training, what AUSTRAC expects to see, and how to document it.
TL;DR
- Section 26F(4)(e) of the Act requires your AML/CTF policies to deal with training for personnel who perform functions relevant to your AML/CTF obligations.
- Rules 5-9 require initial and ongoing training, matched to the person’s function, the risks relevant to it and their responsibilities under your policies, in a form they can readily understand.
- AUSTRAC expects a training plan by role, a register of completion and due dates, and monitoring of effectiveness.
- You may outsource delivery, but you stay responsible for the result. AUSTRAC’s free e-learning alone does not meet your obligation.
- Keep training records until 7 years after they stop being relevant to showing compliance (section 116), so you can produce them in an examination.
Table of Contents
- What the Act and Rules ask your policies to say
- Who must be trained in a real estate agency
- What the training must cover
- What AUSTRAC expects your policies to show
- Training before you provide designated services
- Records that prove the training happened
- How training fits with the rest of your program
- The cost of getting it wrong
- A workable approach for an agency
- Our perspective
- Building your training manual with AML Guard
- FAQ
- Sources
What the Act and Rules ask your policies to say
Training is not a separate checklist item that sits beside your AML/CTF program. It is a required part of the program itself. Section 26F(4)(e) of the Act, together with section 5-9 of the AML/CTF Rules 2025, requires your policies to provide for training of people who are employed or otherwise engaged and who perform functions relevant to your obligations. AUSTRAC’s AML/CTF training guidance states that this training must help those people understand your obligations under the Act, Rules and regulations, and your ML/TF risks.
The Rules add four qualities that a supervisor will look for in your written policies:
- Initial and ongoing. Training happens when a person is employed or engaged, and it continues after that.
- Appropriate to the function. A principal, a sales agent and an administrator who collects identity documents do not need identical content.
- Tied to relevant risks and responsibilities. Training addresses the ML/TF risks that touch the person’s work and what your policies require them to do.
- Readily understandable. Content and delivery suit the audience, including staff whose first language is not English.
The practical consequence is that a policy sentence such as “all staff will receive AML training” is not enough. Your policies should state who is trained, on what, in what form, who is responsible for scheduling it and how completion is tracked.
Who must be trained in a real estate agency
The obligation attaches to personnel, and AUSTRAC’s guidance describes personnel as anyone employed or engaged to perform AML/CTF functions. That reaches beyond employees on your payroll. Contractors, licensed agents working under your licence and outsourced staff can all fall within it if they perform relevant functions.
The starting point is whether your business provides designated services. AUSTRAC’s real estate designated services page explains that a business with a geographical link to Australia that provides one or more designated services has AML/CTF obligations. It identifies buyer’s or seller’s agents, and property developers who sell house and land packages, off-the-plan apartments or blocks in new subdivisions without independent agents, as likely providers.
Once you are in scope, build the list of people by function rather than by job title:
| Function | Typical people | What their training should centre on |
|---|---|---|
| Governance and oversight | Principal, directors, senior managers | Their duty to approve and oversee the program, and the risk profile of the agency |
| AML/CTF compliance officer | Appointed compliance officer | The Act, reporting thresholds, enhanced due diligence, program review and communication with AUSTRAC |
| Client-facing | Sales agents, buyers agents, sales associates | Recognising red flags, customer due diligence conversations, escalation and tipping off |
| Onboarding and administration | Staff who collect identity documents and process client records | Verification steps, record keeping and how to escalate concerns |
| Property management involved in sales | Property managers who touch a sale | Whether their activity falls within your designated services |
If you are unsure how property management fits, our guide on whether AML/CTF applies to property management sets out the distinction.
State licensing reinforces this. The NSW Government’s CPD requirements for property professionals state that Class 1 licence holders in relevant areas of practice must also complete AUSTRAC’s Smart real estate agent’s guide to AML/CTF course. That is a licensing matter in New South Wales. It sits alongside, and does not replace, the training your own policies require.
What the training must cover
AUSTRAC’s training guidance describes role-specific content across initial, ongoing and enhanced customer due diligence (CDD), suspicious matter reports (SMRs) and threshold transaction reports (TTRs), record keeping, and the governance of the AML/CTF program. For a real estate agency, a sound curriculum includes:
- What money laundering, terrorism financing and proliferation financing are, and why property is attractive to those who launder funds.
- The agency’s own risk assessment: which client types, funding sources, transaction structures and locations your business has rated higher risk.
- How to carry out CDD for individuals, companies and trusts, and when enhanced due diligence applies.
- How to spot red flags specific to property sales and purchases.
- How to raise an internal concern and how the SMR pathway works.
- What tipping off is and why disclosing a report or suspicion is an offence.
- Record keeping duties and how to use the systems your agency has chosen.
The second bullet is where generic courses fall short. AUSTRAC’s Smart real estate agent’s guide to AML/CTF is a train-the-trainer package for frontline professionals and agency leaders, and it helps them recognise risks and indicators, complete CDD, manage client conversations and escalate. The page itself says the package is educational and not exhaustive, and that it does not fulfil your obligation to provide training specific to your business and its ML/TF risks.
In other words, public material gives your people the framework. Your policies must supply the part only you can: your risk assessment, your procedures, your systems and your escalation path.
What AUSTRAC expects your policies to show
AUSTRAC’s training page sets out what a supervisor expects to find behind a training policy. Three things stand out.
A training plan by role. The plan identifies each group of personnel, the content suited to their function and risk exposure, and a schedule. It should also account for changes in law, guidance and emerging risks, so that material is updated rather than reused unchanged.
A register of completion and due dates. You need a single place that shows who has been trained, when, on what, and when their next training falls due. A register that records only past completions does not show that you manage the schedule.
Monitoring of effectiveness. Completion is not the same as understanding. AUSTRAC’s guidance contemplates that you check whether training works, for example through assessments, supervision, peer review and follow-up on errors found in CDD files or internal reports.
AUSTRAC lists a range of acceptable delivery methods: online or in-person courses, on-the-job training, reviewing publications, industry events, regular communications, and informal education such as supervision and mentoring. Your policies can combine them, provided the combination is tailored, appropriate and understandable for each role.
Outsourcing delivery without outsourcing responsibility
You may engage an external provider to deliver training. AUSTRAC’s position is that the reporting entity remains responsible for making sure the training is tailored, appropriate and understandable. Practically, that means your policies should state who selects and reviews external content, how you confirm it reflects your risk assessment, and how completion data returns to your own register.
The same logic applies to AUSTRAC’s e-learning. It is a useful free resource, and it is a sound component of a program. It is not, on its own, evidence that you trained personnel on your ML/TF risks and your policies.
Training before you provide designated services
Training belongs at the front of onboarding, not after the first client file. A new agent or administrator who will conduct or review CDD should be trained on your policies before handling a verification. Your policy should say this explicitly and name who confirms it, such as the compliance officer, before system access or client responsibilities are granted.
This sequencing also protects your CDD records. If a file was completed by someone who had not been trained, an examiner reviewing it will have reason to question both the file and your governance. Leaving a gap between starting work and receiving training is the easiest weakness to avoid.
How often refresher training should occur is covered in a separate article. For this guide, the point is narrower: your policies must provide for ongoing training and name the mechanism that triggers it.
Records that prove the training happened
Training is an obligation you must be able to demonstrate. Under section 116 of the Act, you must keep records reasonably necessary to show you complied with your personnel training obligations. AUSTRAC’s record keeping overview lists the records that may demonstrate compliance with the training obligation:
- Training content and materials that reflect your AML/CTF program policies and procedures.
- Training schedules or plans, such as an annual or periodic calendar showing topics, dates and target staff.
- A register of attendance, results and completion.
- Action taken in response to non-attendance.
The training guidance goes further and suggests keeping delivery methods, assessments, participant details and training history. A practical record for each person includes their name and role, the date, a description of the content covered rather than only a course title, the delivery method, evidence of completion and the version of your AML/CTF program the training was based on. Linking each record to a program version matters because it shows the training matched the policies in force at that time.
On retention, section 116 requires you to keep these records until 7 years after they are no longer relevant to showing compliance, as AUSTRAC’s record keeping overview also explains. For a closer look at what to keep and where, see our guide to AML training records in Australia.
How training fits with the rest of your program
Training is one of several linked obligations. AUSTRAC’s overview of your obligations pairs it with personnel due diligence: you assess the skills, knowledge, expertise and integrity of personnel, then train them so they understand your obligations and know how to follow your policies, procedures and systems.
The links run in several directions:
- Risk assessment to training. Your business-wide ML/TF risk assessment decides which risks the training must address. If the assessment changes, training content should change with it. Our guide on the AML risk assessment for real estate agencies explains how to build that foundation.
- Policies to training. Training teaches the procedures your policies prescribe. If the two diverge, staff learn one process and are measured against another.
- Governance to training. Senior management approves the program, the governing body oversees it, and the compliance officer manages day-to-day compliance, so the compliance officer is the natural owner of the training plan and register.
- Review to training. Internal reviews and independent evaluations of the program test whether it works, and training records are part of the evidence they examine.
This is why the strongest training programs are produced from the same source material as the rest of the program, not collected from separate places. If you are working through your wider obligations, the AML/CTF compliance checklist for real estate agents places training among the other requirements, and when CDD starts explains why the people doing it need to be trained first.
The cost of getting it wrong
Training gaps rarely fail in isolation. They tend to surface as weak CDD files, missed escalations or an inability to produce records. AUSTRAC’s page on the consequences of not complying notes that a civil penalty ordered by the Federal Court can be up to 100,000 penalty units for a body corporate and up to 20,000 penalty units for anyone else, and section 26F(4)(e) makes training a required part of your policies. For an agency owner, the lesson is to treat a thin training policy as a program defect, not an administrative detail.
A workable approach for an agency
A short sequence turns the requirements into something you can run:
- List personnel by function. Include contractors and anyone engaged to perform relevant tasks.
- Map content to each function. Use your risk assessment as the source for risks and red flags.
- Write the training section of your policies. State who is trained, on what, by what method, and who is accountable.
- Use public material as a component. AUSTRAC’s resources help, and your own content supplies agency-specific procedures.
- Record every completion. Capture name, role, date, content, method, evidence and program version.
- Monitor effectiveness. Review assessment results and file quality, and act on what you find.
- Retain the evidence until 7 years after it stops being relevant. Keep it where the compliance officer can retrieve it quickly.
For the agency-specific angle, including what agents and principals need to cover, see AML training for real estate agencies.
Our perspective
Most agencies we speak to understand that staff need training. The harder question is whether the training is demonstrably connected to the rest of the AML/CTF program, because that connection is what a supervisor tests.
A downloaded template or a generic course can describe the regime in general terms. It cannot know your risk assessment, your policies or your staff roles. When those documents are written separately, they drift apart, and the training stops matching what your people are actually asked to do.
That is why AML Guard’s guided wizards produce the risk assessment, the AML/CTF program, a customer acceptance policy and the training manual, and can pre-fill from your risk assessment. A downloaded template starts with no knowledge of your risk assessment; a manual built this way starts from it.
The platform automates the records and the lookups. Judgement stays with your officers, where the law places it.
AML Guard
Building your training manual with AML Guard
If you are a principal or compliance officer who wants your training manual to start from your own risk assessment, AML Guard’s guided wizard produces it alongside the risk assessment, the AML/CTF program and a customer acceptance policy, and can pre-fill from your risk assessment, so each role is trained on what your program says.
AML Guard is not self-service; every firm starts with a demo. Book a demo to walk through the training manual with our team, or see the pricing page for the subscription and per-check fees.
FAQ
Does every staff member in a real estate agency need AML/CTF training?
Training is required for personnel who perform functions relevant to your AML/CTF obligations, and that includes anyone employed or otherwise engaged to do so. In an agency this commonly covers principals, the compliance officer, agents, sales associates and administrators who process client identification. Decide by function, and record the reasoning in your plan.
Is AUSTRAC’s e-learning enough to meet the training requirement?
No. AUSTRAC’s free resources, including the Smart real estate agent’s guide, are useful components, but AUSTRAC states that the guide does not satisfy your obligation to provide training specific to your business and its ML/TF risks. Your policies must add your own risks, procedures and escalation path.
Can we outsource AML/CTF training to an external provider?
Yes, you can outsource delivery. You remain responsible for making sure the training is tailored to each role, appropriate and readily understandable, and for keeping the records that show it was completed.
What records should we keep to show training was completed?
Keep the training content, the schedule or plan, and a register of attendance, results and completion, plus any action taken after non-attendance. Each entry should show the person’s name and role, the date, the content, the delivery method and the evidence of completion. Keep them until 7 years after they stop being relevant to showing compliance (section 116).
Sources
- AML/CTF training | AUSTRAC
- Real estate designated services | AUSTRAC
- Continuing Professional Development requirements for property professionals, NSW Government
- Smart real estate agent’s guide to AML/CTF | AUSTRAC
- Record keeping overview | AUSTRAC
- AML/CTF obligations factsheet for Tranche 2 reporting entities | AUSTRAC
- Your obligations | AUSTRAC
- Consequences of not complying | AUSTRAC
Recommended
- AML training real estate: what agencies must do
- AML/CTF Compliance Checklist for Real Estate Agents: What You Need Before 1 July 2026
- AML risk assessment for real estate agencies
- Does AML/CTF Apply to Property Management?
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