Aspects of the services offered by the real estate industry have been identified as being attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

Why will real estate have AML/CTF obligations?

Real estate can be an attractive channel for criminals wishing to launder illicit funds.

Criminals can purchase a property using illicit funds, live in the property purchased with illicit funds, renovate the property (using illicit funds) to improve its value and sell the property later for a capital gain.

The ultimate beneficial ownership of real estate can also be easily concealed, making it an attractive asset class for criminals.

What are the ML/TF risks faced by the real estate industry?

The Money Laundering and Terrorist Financing (ML/TF) risks associated with the real estate sector include:

  • The use of third parties to buy and sell properties
  • The use of loans and mortgages (for example, criminals take out a mortgage to buy a property and pay back the mortgage using lump sum cash payments)
  • Manipulating property values (that is, criminals buy and sell real estate at a price above or below market value)
  • Structuring cash deposits to buy real estate
  • The use of complex company structures and multiple accounts to disguise the real purpose of a property transaction and disguise its’ true ownership
  • Buying and leasing properties, but providing the tenant with illicit funds to pay the rents
  • Buying a property using illicit funds with the intention of conducting further criminal activity at the property
  • Using illicit funds to renovate properties


Businesses within the real estate industry captured by the AML/CTF obligations must ensure their organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures. This is a critical first step in complying with the AML/CTF Act and Rules.

What services may be covered by AML/CTF obligations?

These are the services offered by the real estate industry that may be included as designated services under the AML/CTF Act.

  • Managing client funds (other than sums paid as fees for professional services), accounts, securities, or other assets
  • Engaging in or giving instructions on behalf of a customer to another person for any conveyancing to affect the grant, sale, or purchase or any other disposal or acquisition of real estate or an interest in land
  • The transfer of a beneficial interest in land or other real property


If you offer or provide one or more of the above services, your business will be subject to AML/CTF obligations.

What is a risk based AML/CTF regime?

The AML/CTF regime is risk-based, which means that your responses to the AML/CTF obligations placed upon you should be risk-based. 

A risk-based AML/CTF regime requires that you understand and address the Money Laundering and Terrorism Financing (ML/TF) risks associated with the services you offer.

You must then design, implement and maintain systems, procedures and controls that appropriately manage and mitigate your ML/TF risks.

How can Initialism help?

Initialism are the AML/CTF experts, so you don’t have to be.

With over 50 years of expert knowledge and real world experience our AML/CTF compliance solutions will help you to navigate your legal and regulatory requirements so that your business complies with its AML/CTF obligations in the fastest and most cost-effective way.

Initialism has a range of AML/CTF solutions to support your business in becoming AML/CTF compliant and maintaining compliance.

AML/CTF compliance solutions for the real estate industry

Initialism is the only AML/CTF consultancy in Australia to have supported Real Estate businesses complying with AML/CTF obligations. Our AML/CTF compliance solutions for the real estate industry draw on unparalleled expertise, knowledge and real-world experience.

Why choose Initialism?


Our expertise covers all AML/CTF disciplines and brings unique perspectives, approaches and solutions to the AML/CTF challenges faced by the real estate industry


Our AML/CTF compliance knowledge includes working with real estate businesses and we understand what compliance means for your business


We have experience in delivering workable AML/CTF compliance to the real estate industry


Our knowledge and expertise has been hard earned and comes from working in the area of AML/CTF for many decades


We have experience in providing tried and tested AML/CTF solutions, regardless of the size and complexity of your real estate business


Our AML/CTF compliance solutions are flexible and can be tailored to your capacity, experience and budget