AML/CTF for Sydney real estate agencies

7 min readUpdated 21 May 2026By Ben Horne

Sydney has the largest concentration of real estate agencies in Australia and the deepest exposure to high-value, foreign-buyer and trust-structured transactions. From 1 July 2026, every sales-side transaction your agency facilitates is a designated service. Caltury runs the AML/CTF workflow for the independent agency and the boutique multi-office group.

What changes for Sydney agencies

Sales-side work is in scope: representing a vendor in the sale of real estate, or representing a buyer in the purchase. Property management is not currently a designated service. So most Sydney sales offices come into scope; pure property-management businesses generally do not.

For the typical Sydney agency mixing sales and property management, enrolment is required on the sales side and the Program needs to cover the sales workflow specifically. Property-management files do not need CDD under the Act, although many agencies will choose to capture some KYC at lease signing for tenancy-management reasons unrelated to AUSTRAC.

Sydney-specific risk indicators

Sydney's prestige eastern suburbs, lower north shore and inner-west markets attract the strongest concentration of foreign-buyer activity in the country. AUSTRAC has publicly flagged these submarkets as elevated-risk for property-laundering typologies. An agency operating in these areas should plan for enhanced due diligence on a meaningful proportion of buyers, not as an exception.

Two specific scenarios appear repeatedly. First, a buyer who fronts an offshore-controlled corporate vehicle and pays deposit funds from a non-AU bank account. Second, a vendor who proceeds to sale through a discretionary trust whose natural-person controllers are deliberately not on the title. Both need careful documentation and risk-rating, not just KYC checkbox-ticking.

Practical workflow inside a Sydney agency

Caltury's typical agency workflow: at listing or buyer engagement, the principal or sales agent creates the customer in Caltury. The customer form branches by entity type (individual, company, trust). Identity verification runs via Stripe Identity. Sanctions and PEP screening runs in the background. The matter is risk-rated automatically based on a Sydney-tuned risk model.

From there, the agency works the deal in its existing CRM and PMS. Caltury is the AML layer alongside, not a replacement for the CRM. When a transaction triggers an AUSTRAC report (foreign-buyer cross-border deposit, structured cash payments, suspicious activity) Caltury drafts the report in AUSTRAC format for the principal to review and lodge.

  • Customer onboarding at listing or buyer engagement
  • Stripe Identity for individual verification
  • Sanctions / PEP screening at intake plus risk-based re-screening
  • Automatic risk rating tuned to Sydney market patterns
  • AUSTRAC report drafting (SMR / IFTI most commonly)
  • 7-year retention vault with append-only audit log

Common questions

Our agency is sales plus property management. Do both sides enrol?

The whole legal entity enrols once. The Program describes which services are designated (sales) and which are not (property management). You do not need a separate Caltury workspace for each side; the same customer database, screening engine and report log services both.

Does Caltury integrate with our REA or Box+Dice agency CRM?

Customer data can be imported by CSV today. Direct API integration with the major AU real estate CRMs is on the roadmap. Most agencies start with a one-off CSV import of their current vendor and buyer list, then add new customers in Caltury at the point of engagement.

Our principal is the named compliance officer. Can salespeople still see records?

Yes. The Practice tier supports 5 named users and the Firm tier supports 15, so a sales team can have individual logins and the principal sits as the AML/CTF Compliance Officer with full visibility. The audit log records actions per user.

What about agencies operating across multiple Sydney suburbs under one brand?

If the agencies operate under one legal entity (one ABN), they enrol once and run one Program covering all offices. If each suburb operates under its own ABN (franchise model), each entity enrols separately. Caltury supports both structures.

This page is general information about Australian AML/CTF obligations. It is not legal advice. AUSTRAC has not reviewed this content. For situations specific to your practice consult an Australian-qualified lawyer or AML/CTF adviser.

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