Tranche 2 AML for real estate & legal: What the AUSTRAC program starter kits mean and how to use them

From 1 July 2026, real estate agencies and legal practices across Australia will be required to have a compliant Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) program in place before delivering certain services.

To support this, AUSTRAC has released dedicated AML Program Starter Kits - tailored tools to help small firms build and maintain their own AML/CTF programs.

But even with a government-issued kit, compliance still takes time, admin, and focus that most small businesses just don’t have. 

Here’s what the kits involve - and how APLYiD helps you get AML-ready in minutes, not months.

Getting started: what's a program starter kit?

AUSTRAC’s Starter Kits offer a structured set of templates and tools designed to help small real estate and legal businesses create their own AML/CTF programs.

Each kit includes:

• A risk assessment covering common sector-specific threats
• AML/CTF policies and procedures to follow
• Step-by-step processes for onboarding, monitoring, and reporting
• Templates and forms to show you’re meeting your obligations

Once customised, these form a complete compliance program aligned with AUSTRAC’s expectations.

Why it matters

Both real estate and legal professionals are common targets for money laundering due to the nature of their services:

• Real estate: property is high value, generates income, and is easy to obscure through complex structures or proxies.
• Legal: law firms can handle large sums, manage cross-border transactions, and create vehicles like trusts or companies that conceal beneficial ownership.

A robust AML/CTF program helps you:

• Protect your business or practice from financial crime
• Avoid reputational, operational and regulatory risk
• Make consistent, defensible decisions about clients and transactions

Who the kits are for 

The starter kits are ideal for smaller, low-risk firms. That means:

• Fewer than 15 staff (including admin and front-line roles)
• Limited services - e.g., property brokering, conveyancing, structuring legal entities
• Mostly Australian-resident clients
• Minimal exposure to overseas transactions or high-risk individuals
• No fully remote self-serve offerings or in-house property sales

If this applies to your business, you’ll need to adapt the materials or build a more comprehensive program. The starter kit is not designed to be used as-is and must be customised before it can be relied on. Completing this step results in a compliant AML/CTF program. Either way, APLYiD supports you in meeting your AML compliance obligations.

What you need to do 

AUSTRAC outlines a three-step process for getting compliant:

Step 1: Customise your program (By 1 July 2026)

• Nominate your AML/CTF compliance officer
• Complete your risk assessment
• Tailor the included policies and forms to your business
• Train your team

Step 2: Use your program (From 1 July 2026)

• Apply AML/CTF checks to each client
• Verify identities, assess risk, monitor transactions
• Report suspicious activity where required

Step 3: Maintain your program (Ongoing)

• Review your program annually
• Have your program evaluated independently every 3 years
• Adapt to any changes in services, risk profile, or regulation
• Stay ready for audits with complete records
• Store all records for 7 years 

Or - let APLYiD handle it for you

At APLYiD, we know most small firms don’t have a compliance team on standby. That’s why we’ve built a no-nonsense AML platform specifically for real estate and legal SMEs - taking the stress, paperwork, and technical complexity off your plate.

Here’s what you get:

• Instant AML setup - start today 
• Built-in workflows aligned to AUSTRAC’s guidance
• Pre-filled dynamic forms and biometric ID checks with 94% success rates
• Real-time risk management and audit-ready record keeping
• Clear, fair pricing - only pay for what you use

We’ve done the hard work so you don’t have to - sourcing the world’s best biometrics, building sector-specific flows, and removing all the friction that causes customer drop-off or internal delay.

Get AML ready without the headaches

Whether you’re a small law firm, or family-owned real estate agency, APLYiD helps you get - and stay – compliant. No worries for you. No effort for your customers. A no-nonsense platform that just works.