What the institutes have done
REINSW, REIV, REIQ and the other state institutes engaged with the Tranche 2 consultation and publish member guidance, webinars and training on enrolment, programs and client identification. Check your institute's website for current material; it is updated as AUSTRAC releases rules and guidance.
Conduct and licensing
Failing to comply with the law of the profession can be a conduct matter with your institute and a licensing matter with your state regulator. Practically, an agency selling with no program and no identification should expect both to take an interest.
Use the guidance, keep your own records
Institute guidance explains the law; it is not your program. Your program must describe your agency. Templates are a fine starting point if you then tailor and adopt them.
Questions people ask
- Does institute training count as AML staff training?
- It can, if it covers your program's content. Record who attended and when.
This guide is general information for real estate agents, buyers agents, property managers, not legal advice. Check AUSTRAC's current guidance for your situation.