AML/CFT for real estate agencies — without it eating your week
The annual report window is 1 July – 31 August. There are no extensions.
Real estate is a DIA-supervised sector, and the 2026 Sector Risk Assessment names the services that matter: sale and purchase of land and property, and trust accounts. Ten minutes of plain-English questions gets you your annual report answers formatted for AML Online — and a scorecard that checks the things agencies actually get caught on.
Get my answers free →Led by a chartered accountant — CA ANZ member, qualified twenty years.
The three things agencies get wrong
CDD timing on live listings
For a sale, customer due diligence falls due once the agency agreement is fully signed — before further agency work. Lease transactions have different, later triggers. Most agencies don't know which listings on their books are already overdue. The free tool asks; the scorecard tells you.
A risk assessment that predates the 2026 SRA
Since 19 May 2026 your risk assessment must incorporate the National Risk Assessment 2024 and the real-estate Sector Risk Assessment 2026. If yours was last reviewed before that, it almost certainly doesn't.
Monitoring that exists but isn't written down
DIA's most common finding in this sector: ongoing monitoring and enhanced due diligence happening informally, with no written findings. "Done but not recorded" counts as not done.