Map the relationships that persist
The agency's customer file should record the relationship type and the risk it carries. A repeat seller with a stable profile is different from a developer whose corporate structure changes before every project. Monitoring design should follow the relationship, not just the file.
- Developers and off-the-plan projects that run across many sales
- Repeat sellers and portfolio owners
- Buyer's agents and introducers who appear across transactions
- Entity owners with changing controllers
Define trigger events
Each trigger should map to a response: re-verify the changed party, re-screen, update the risk rating or escalate. The program should name the response so the trigger list is operational.
- A new project or listing from an existing customer
- A change in ownership, directors or trustees
- A new source of funds or payment structure
- An uncooperative purchaser or last-minute party change
- A suspicious pattern reported by the sales team
Review cycles that fit agency work
AUSTRAC does not prescribe one universal calendar. An agency can anchor reviews to transaction events: every new listing, every new sale, every off-the-plan milestone. For dormant relationships, a risk-based periodic review is still needed so files do not age silently.
Record the cycle and the rationale in the program. If the agency uses continuous screening, record how results are received, reviewed and filed; if not, set the re-screening dates explicitly.
Monitoring to reporting
Monitoring has one purpose: to surface what needs a decision. The agency's escalation path should connect the sales team's observation to a documented assessment and, where required, a report.
- Escalate confirmed patterns to the compliance officer
- Assess each pattern against the statutory suspicion test
- Lodge SMRs within the deadline and protect SMR-related information
- Document cleared observations with reasons
Official sources
Use these primary AUSTRAC pages to confirm the current rules and apply them to your circumstances.
Frequently asked questions
Does a real estate agency need ongoing monitoring?
Yes, where it has ongoing relationships or repeat transactions. AUSTRAC's ongoing CDD framework applies to relationships, and the agency should define triggers and cycles that fit its work.
How often should an agency re-screen a customer?
On a risk-based cycle defined in the program and on triggers such as new listings, ownership changes or suspicious patterns.
What should the sales team watch for?
Last-minute party changes, unexplained funding, third-party payments, cash offers and uncooperative purchasers - and the team should know the escalation path.
Do cleared observations need to be recorded?
Yes. The record shows that monitoring happened and why an observation did not escalate, which is as important as the reports that are lodged.
Put it into practice
Cassandra AML turns these obligations into a working system: designated-service decisions, customer due diligence, screening, monitoring and reporting records — hosted in Sydney, free to start.
This guide is general information for Australian professionals. It is not legal advice and does not replace the AML/CTF Act, the AML/CTF Rules or AUSTRAC guidance. Confirm your specific obligations with AUSTRAC or a qualified legal adviser. See our editorial and correction standards.