Do I actually need to comply if I'm a small agency? +
Yes. Every real estate agency that facilitates the sale, purchase or transfer of property in Australia is a Tranche 2 reporting entity under the AML/CTF Act — regardless of size. There are no exemptions for small agencies. Penalties apply per contravention, and AUSTRAC commenced proceedings against smaller entities in 2025. The "too small to notice" defence is no longer credible.
I've already signed up with a cheap AML software. Am I covered? +
Software alone does not meet your legal obligations. The AML/CTF Act requires a tailored, risk-based AML/CTF program, ongoing customer due diligence, transaction monitoring with human judgment, staff training, and annual reporting to AUSTRAC. Workflow software supports these processes — it does not replace them. If your current solution cannot show you a defensible audit file, you are exposed.
What does the $1,150 implementation fee cover? +
The setup and implementation fee covers the full onboarding of your agency onto the Property360 platform, the development of your tailored AML/CTF program (Part A and Part B), configuration of your role-based portals, integration of GreenID identity verification, initial staff training session, and production of your baseline compliance documentation — everything you need to be AUSTRAC-compliant from day one.
What is the CFO Model and who is it for? +
The CFO (Compliance & Finance Officer) Model places a licensed finance professional inside your agency who manages both your AML compliance obligations and builds a mortgage broking income stream under your brand. AML compliance has been in the finance industry since 2008 and your CFO is already well versed with understanding the mechanics of AML Compliance. This Model is designed for single-office and multi-office agencies who want to convert the mandatory compliance cost into a commercial asset — generating finance commission income, building a saleable loan trail book, and receiving additional property listing referrals. It is the only model of its kind in the Australian market.
Under the CFO Model, does my client database stay with me? +
Absolutely — and this is contractually guaranteed. Your client data is stored in your own Property360 portal, hosted in Australia (Sydney), and never shared with, sold to, or accessible by any third party including Property360 personnel beyond the compliance function. Your database is your most valuable asset and it remains 100% yours.
How secure is the Property360 platform? +
The platform is built on enterprise-grade infrastructure: Vercel (SOC 2 Type II), Supabase database in Sydney (SOC 2 Type II, AES-256 encryption at rest), Cloudflare DDoS and WAF protection (ISO 27001), GreenID/Equifax identity verification (ISO 27001), and Stripe payment processing (PCI DSS Level 1). All data is encrypted in transit (TLS 1.3) and at rest (AES-256). Sessions expire after 45 minutes. Full audit logging of all actions with timestamp and IP. 7-year data retention as required by the AML/CTF Act.
What is the AUSTRAC deadline and what happens if I miss it? +
Tranche 2 AML/CTF obligations commence for real estate agencies on 1 July 2026. AUSTRAC enrolment opened 31 March 2026. The final enrolment deadline is 29 July 2026. Civil penalties for non-compliance are up to $33 million per contravention for corporations and $6.6 million for individuals. AUSTRAC's first independent audit evaluation is proposed by 1 July 2029 — meaning agencies that aren't compliant by mid-2026 will be scrambling to catch up before audit day.
Does property management or leasing activity need to comply? +
No. The Tranche 2 obligations apply specifically to the sale, purchase, transfer or auctioning of real property. Pure property management (rent collection, maintenance, leasing) is explicitly out of scope. However, if your agency is involved in any sales activity, that activity is in scope — and the compliance framework must be in place for the whole agency, not just individual agents.
