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Introduction
If you're running a small real estate agency or conveyancing firm, you're probably wondering who should be your AML/CTF Compliance Officer when Tranche 2 starts. For most small firms, that person will be you - the owner. This guide shows you exactly what the role involves and how to make it manageable alongside running your business.
What Tranche 2 Means for Founders/Principals
Every real estate and conveyancing business needs to appoint an AML/CTF Compliance Officer by July 2026. This person is your official contact with AUSTRAC and takes responsibility for your anti-money laundering procedures.
In a small firm of under 10 people, this will almost certainly be you as the owner or principal. That's completely normal and AUSTRAC expects it. You don't need to hire someone special - you just need to understand what you're signing up for and how to make it work without overwhelming yourself.
The Core Obligations (Real Estate & Conveyancers, Plain English)
KYC/KYB and CDD
Your Compliance Officer ensures client identification procedures are followed on every transaction.
Ongoing Monitoring & Red Flags
They decide when something suspicious needs reporting and make the final call on risk ratings.
Reporting
The Compliance Officer submits (or delegates submission of) SMRs, TTRs and IFTIs to AUSTRAC.
Record-Keeping (7 Years)
They ensure all required records are kept properly and can be retrieved when needed.
AML/CTF Program
The Compliance Officer maintains your written procedures, arranges training, and manages independent reviews.
Quick Wins You Can Action This Week
- Accept that as the owner, you're the logical choice - you already carry ultimate responsibility for compliance anyway
- Block out 2 hours weekly in your calendar specifically for AML compliance tasks (Friday afternoon often works well)
- Create a simple compliance folder structure in your cloud storage that only you and one backup person can access
- Identify your backup person - someone who can handle urgent reports if you're unavailable
- Start a basic compliance diary - note decisions, concerns, and actions taken on client matters
What Does a Compliance Officer Actually Do?
Daily tasks (5-10 minutes)
Quick review of any new clients onboarded, check if any suspicious matters have been flagged by staff, sign off on any high-risk clients before proceeding.
Weekly tasks (1-2 hours)
Review the week's transactions for anything unusual, check international transfers need IFTI reports, ensure KYC/KYB documents are properly filed, brief staff on any new risks or concerns.
Monthly tasks (2-3 hours)
Update risk register if needed, review and file any reports submitted to AUSTRAC, check staff are following procedures, update training records, review any regulatory updates from AUSTRAC.
Annual tasks
Arrange independent review (every 3 years minimum), update your AML/CTF Program document, conduct formal staff training session, complete AUSTRAC compliance report.
The reality for small firms
Most weeks, this takes less than 2 hours total. It's not a full-time job unless you're processing hundreds of transactions monthly.
For Small Firms: Making It Manageable
You don't need to be an expert immediately. AUSTRAC understands small businesses learn as they go. Document your decisions and show you're trying to comply - that matters more than perfection.
Delegate the doing, not the deciding. Your admin can collect KYC documents, but you make the call on whether they're sufficient. Your property manager can flag concerns, but you decide if it needs reporting.
Use templates religiously. Don't recreate the wheel for every decision. Build standard responses: "KYC approved - standard residential buyer", "Enhanced CDD required - foreign purchaser", "SMR filed - unexplained funds source".
Set clear escalation triggers. Tell staff exactly when to interrupt you: cash over $5,000, any international transfer, any client who refuses to provide ID, any transaction that feels wrong.
Choosing Someone Else as Compliance Officer
Sometimes appointing someone else makes sense, especially if you have a trusted senior manager or if you're frequently travelling. If you go this route, here's what to consider.
Good candidates
Office manager with 5+ years experience, senior property manager who understands procedures, part-owner who's actively involved in operations, or your conveyancing practice manager.
Poor candidates
Junior staff (lack authority), part-time employees (availability issues), external consultants (need daily presence), or anyone who can't make tough calls under pressure.
Critical requirement
This person needs authority to say "no" to transactions, even if it costs commission. They need your complete backing when they make compliance calls.
The Official Appointment Process
- Document the appointment in writing, even if it's yourself. Include: name, title, date appointed, reporting line (board or owner), and primary responsibilities.
- Update AUSTRAC when you enroll (by 29 July 2026). They need the Compliance Officer's name, contact details, and position in the business.
- Notify your team formally. Everyone should know who makes final compliance decisions and who to escalate concerns to.
- Include in your AML/CTF Program document. Part B should clearly identify your Compliance Officer and their specific duties.
- Set backup arrangements for when the Compliance Officer is unavailable. Name a specific person, not just "senior management".
Common Concerns From Small Firm Owners
"I don't have time for this."
You're already responsible for trust accounts, licensing, and other compliance. This adds maybe 2 hours weekly - less than managing your social media. The penalties for getting it wrong are far worse than finding the time.
"What if I make a mistake?"
AUSTRAC distinguishes between honest errors and willful non-compliance. Document your reasoning, fix mistakes quickly, and show you're trying to comply. That's what matters.
"Can I outsource this completely?"
No. You can get help with procedures and training, but someone inside your business must own day-to-day decisions. Consultants can advise, not decide.
"I'm selling in two years - why bother?"
Your business value drops significantly if you're non-compliant. Buyers will check. Plus, personal liability follows you even after selling.
14-Day Action Plan (Printable)
Day 1-2
Accept you're the Compliance Officer (or identify who will be)
Day 3-4
Draft appointment letter, even if appointing yourself
Day 5-6
Create secure compliance folder with restricted access
Day 7-8
Set recurring calendar blocks for compliance tasks
Day 9-10
Identify and brief your backup person
Day 11-12
Create simple decision log template
Day 13-14
Brief all staff on who's the Compliance Officer and what that means
Red Flags That You Need Help
These signs suggest you might need external support or a different Compliance Officer:
- You're processing over 50 transactions monthly and can't keep up
- You've had multiple compliance breaches in other areas
- You're frequently absent from the business (more than 8 weeks annually)
- Your business structure is complex (multiple entities, international connections)
- You're finding yourself avoiding compliance decisions
FAQs (Real Estate & Conveyancers)
Q: Can my office manager be the Compliance Officer?
Yes, if they have sufficient seniority, understanding of the business, and authority to make decisions that might cost money.
Q: Do I need special qualifications?
No formal qualifications required. AUSTRAC provides free training. Common sense and business experience matter more than certificates.
Q: What's my personal liability?
As Compliance Officer, you can face personal penalties if you're negligent or reckless. But following reasonable procedures and documenting decisions provides strong protection.
Q: How much should I budget for this role?
For small firms where the owner takes the role: budget 2-3 hours weekly of your time, plus $2,000-5,000 annually for tools and training. If appointing someone else, add 10-15% to their current salary.
Q: Can two people share the role?
No. One person must be the designated Compliance Officer. But you should definitely have a backup person identified.
Conclusion
Appointing a Compliance Officer doesn't need to be complicated. For most small real estate and conveyancing firms, the owner takes this role and spends a couple of hours weekly on it. Document the appointment, set up simple systems, and build compliance into your regular routine rather than treating it as something separate. Remember - you're already managing compliance in other areas of your business. This is just one more, and with the right approach, it's entirely manageable.
Additional Information
For more comprehensive information on Tranche 2 AML/CTF reforms and regulatory obligations, visit AUSTRAC's official website at: https://www.austrac.gov.au/about-us/amlctf-reform/new-amlctf-rules