Lumiere AUSTRAC — Complete AML/CTF Compliance Platform

Obligation 1 — AUSTRAC Enrolment

Must enrol with AUSTRAC before providing any designated service from 1 July 2026. Enrolment deadline: 29 July 2026. Free to enrol at austrac.gov.au.

Agency Readiness Tracker

Tick each obligation as completed. AI generates a gap report with specific actions.

Confirmed designated service provider status

Required · Confirm at austrac.gov.au/reform/tranche-2

AUSTRAC Online account created

Required · Register at online.austrac.gov.au

Enrolment form completed and submitted

Required · Deadline 29 July 2026

AML/CTF Compliance Officer formally appointed

Required · Document in writing. Typically the Licensee in Charge.

ML/TF risk assessment completed (Tab 3)

Required · Must be documented before programme finalised

AML/CTF Programme written and approved (Tab 2)

Required · Senior manager must sign before 1 July 2026

CDD procedures operational (Tab 4)

Required · All clients verified before service commences

Sanctions & PEP screening in place (Tab 5)

Required · Every client screened against DFAT + UN lists

SMR procedure documented and understood (Tab 6)

Required · All staff understand tipping-off prohibition

7-year record keeping system operational (Tab 9)

Required · All CDD, SMR, TTR and programme materials

All staff completed AML/CTF training (Tab 11)

Required · Certificates retained in training register

Ongoing monitoring schedule set (Tab 8)

Required · Periodic re-screening of existing clients

READINESS SCORE0 / 12

Complete obligations above to build your compliance foundation.

AUSTRAC Website →

AI Compliance Gap Report

Key Dates & Obligations

Date	Obligation	Status
31 Mar 2026	Enrolment opens	OPEN
1 Jul 2026	All AML/CTF obligations commence	—
29 Jul 2026	Enrolment hard deadline	URGENT
30 Sep 2027	First annual report due	Plan now
Every 3 yrs	Independent evaluation	Ongoing

Penalties — Know the Risk

CIVIL PENALTIES

Up to 100,000 penalty units per contravention. At $330/unit = up to $33M. Federal Court enforcement. Published publicly.

TIPPING-OFF — CRIMINAL OFFENCE (s.123)

Telling anyone an SMR has been filed: 2 years imprisonment OR 120 penalty units, or both.

STRUCTURING — CRIMINAL OFFENCE

Breaking cash into sub-$10K payments to avoid TTR: criminal offence regardless of source.

AML/CTF Programme Generator

Based on AUSTRAC's Real Estate Starter Kit. Generates a full written programme covering all 8 mandatory sections — ready for senior manager sign-off.

Agency / Business Name

Principal / Licensee in Charge (LIC)

AML/CTF Compliance Officer

Office Location(s)

ABN

Designated Services Provided

Staff Count

Transaction Range

International Buyer Exposure

Highest ML/TF Risk in Your Business

AML/CTF Programme Document — All 8 AUSTRAC Sections

Complete the form and generate. Your programme covers: 1. Agency overview and designated services 2. Compliance Officer appointment 3. ML/TF risk assessment 4. Customer Due Diligence procedures 5. Sanctions and PEP screening procedures 6. Suspicious Matter Reporting procedures 7. Record keeping — 7-year retention 8. Staff training and annual review Ready for senior manager signature and AUSTRAC compliance from day one.

AUSTRAC Requirement

Every designated service provider must conduct and document a Business-Wide ML/TF Risk Assessment before 1 July 2026. This register is your documented evidence.

ML/TF Risk Assessment Matrix

Rate each risk category. The matrix calculates your inherent risk score and residual risk after controls.

Agency Name

Assessment Date

Risk Category

Likelihood

Impact

Control

OVERALL RESIDUAL RISK—

Complete the matrix above

Risk Assessment Narrative

Risk Category Reference

Category	Key Risk Indicators
Client	PEPs, foreign nationals, complex structures, unknown source of funds
Product/Service	High-value sales, off-market transactions, buyer's agency
Delivery Channel	Online-only relationships, no face-to-face, intermediaries
Geography	High-ML jurisdictions, offshore funds, international buyers
Transaction	Cash components, rapid resales, above/below market price
Beneficial Ownership	Complex trust/company structures, nominee purchasers

Senior Manager Sign-Off

This risk assessment must be approved by a senior manager and reviewed at least annually.

Approved By

Title

Date of Approval

Next Review Date

Customer Due Diligence

Complete BEFORE providing any designated service. Verify identity, confirm structure, assess risk.

Client Full Name

Client Type

Nationality / Residency

Transaction Value

Source of Funds

Red Flags (tick all observed)

Reluctant or unable to provide identity documents Inconsistent or changing story about identity or funds Request to purchase in third party's name without explanation Unusual urgency to complete or settle Cash or cryptocurrency payment offered Purchase price significantly above or below market value Funds from unknown offshore sources Client may be PEP or on sanctions list (screen in Tab 5)

CDD Assessment Report

Identity Verification — 100 Point Check

Australian law requires 100 points of identity documentation. Record each document collected and verified.

Add ID Document

Document Number / Reference

Verified By

Verification Method

How Identity Verification Works Here

The 100-point check above is a manual document recording system — you record which documents you personally sighted and verified. This is fully AUSTRAC-compliant: the AML/CTF Rules allow manual verification of identity documents sighted in person.

It does NOT connect to government databases to verify documents electronically. That requires a third-party identity verification API (APLYiD, Green ID, PEXA Clear).

Month 3 roadmap: APLYiD integration — send a verification link to client's phone, they photograph ID, biometrics checked against government database, result returned in 30 seconds and auto-saved here.

AUSTRAC Requirement — Mandatory for Every Client

You must screen every client against the Australian DFAT Consolidated Sanctions List, UN Security Council Sanctions List, and check for Politically Exposed Person (PEP) status before providing any designated service.

Sanctions & PEP Search

Enter the client's details to screen against live sanctions lists. Results are recorded in your audit trail.

Full Name to Screen

Date of Birth (if known)

Nationality

Also screen associated entities (optional)

SCREENING SOURCES

Australian DFAT Consolidated Sanctions List UN Security Council Consolidated List OFAC SDN List (USA Treasury) PEP Status Assessment (AI-assisted)

PEP Definition

A Politically Exposed Person (PEP) is someone who holds or has held a prominent public position. PEPs require Enhanced CDD regardless of transaction value.

Domestic PEPs include:

Members of Parliament (Federal & State) · Senior government officials · Senior judiciary · Senior military & police · Board members of major state-owned entities · Senior executives of political parties

Foreign PEPs include:

Heads of state · Cabinet ministers · Ambassadors · Senior central bank officials · Senior foreign military · Their immediate family and known close associates

Manual Screening Links

Use these official government search tools to manually verify results.

DFAT Consolidated List →Australian government UN Sanctions Search →United Nations OFAC SDN Search →US Treasury

Automated Live Screening — Coming Month 3

Direct API connection to DFAT, UN and Refinitiv World-Check for automated real-time screening will be added. The AI-assisted screening above cross-references published list patterns and is AUSTRAC-compliant as a documented manual check.

⚠ TIPPING-OFF — SECTION 123 AML/CTF ACT 2006 — CRIMINAL OFFENCE

Once you decide to file an SMR, you must NOT tell the client, their solicitor, their broker, or any other person that a report has been or is being considered. Penalty: 2 years imprisonment OR 120 penalty units, or both. If asked why you need information: "We are required to collect certain information from all clients as part of our standard compliance procedures."

Suspicious Matter Report — AUSTRAC Online Format

Complete the form and generate. Formatted for direct submission via AUSTRAC Online (online.austrac.gov.au). Copy to clipboard and paste. Keep a copy — retain for 7 years.

SMR Timing Rules

Type	Deadline
Terrorism financing suspicion	24 HOURS — call 1300 021 037
All other suspicious matters	3 business days from forming suspicion

The 3-day clock starts when you form the suspicion — not when you decide to act. Document the date immediately.

Threshold Transaction Report (TTR)

File a TTR when a client pays $10,000+ in physical cash. Bank transfers and cheques do NOT trigger TTR. Lodge within 3 business days via AUSTRAC Online.

Property Address

Cash Amount (AUD)

Date of Transaction

Client Name

Purpose of Payment

Currency

Reporting Agent

Threshold Transaction Report

TTR Quick Reference

TRIGGERS A TTR

$10,000+ in physical cash · Foreign currency equivalent · Multiple cash payments totalling $10,000+ (structuring)

DOES NOT TRIGGER A TTR

Bank transfers (EFT / BECS) · Bank cheques · Personal cheques · Credit/debit card · Electronic deposits

STRUCTURING — CRIMINAL OFFENCE

Deliberately breaking cash into sub-$10K amounts to avoid TTR. File an SMR and do not complete the transaction.

HOW TO LODGE

AUSTRAC Online at online.austrac.gov.au · Within 3 business days · Retain copy for 7 years

AUSTRAC Requirement — Ongoing Monitoring

CDD is not a one-time event. You must monitor existing client relationships for material changes and re-screen when risk indicators change. High-risk clients require more frequent review.

Add Client to Monitoring Schedule

Track all clients requiring periodic re-screening. System alerts when review is due.

Client Name

Initial CDD Date

Risk Level

Client Type

Property / Transaction

Notes

Monitoring Schedule

Monitoring Triggers — Act Immediately if:

TRANSACTION CHANGE

Client changes funding source · Transaction price changes significantly · New parties added to transaction

CLIENT CHANGE

Client's circumstances change materially · New information about PEP status · Adverse media or sanctions hit

BEHAVIOUR CHANGE

Unusual requests or instructions · Reluctance to provide updated information · Third party involvement appears

Add Compliance Record

Every action is timestamped and hashed. Records are tamper-evident — each entry is linked to the previous via SHA-256 hash chain.

Record Type

Client / Subject

Completed By

Date

Notes

Audit Trail SHA-256 HASH CHAIN

7-Year Retention Schedule

Record Type	Retention Period	Legal Basis
CDD documents (all clients)	7 years from end of relationship	AML/CTF Act s.116
AML/CTF Programme + all updates	7 years from creation/update	Available to AUSTRAC on request — no notice required
Every SMR filed	7 years from filing date	Even if no investigation resulted
Every TTR filed	7 years from transaction date	All cash transactions $10K+
Staff training records	7 years from completion	Name, date, content, certificate
Annual compliance reports	7 years from submission	First report due 30 Sept 2027
Risk assessments	7 years from last update	Including all annual reviews
Sanctions screening results	7 years from screening date	Record of every check with result

Annual Compliance Report Generator

First reporting period: 1 July 2026 – 30 June 2027. Report due 30 September 2027. Submit via AUSTRAC Online.

Agency Name

Compliance Officer

Period From

Period To

Total Designated Service Transactions

SMRs Filed

TTRs Filed

Staff Training Completion

Programme Changes This Period

Issues or Breaches Identified

Annual Compliance Report — AUSTRAC Submission Ready

Complete the form and generate your annual report. Review, finalise and submit via AUSTRAC Online between 1 July and 30 September 2027.

Independent Evaluation

Your programme must be independently evaluated at least every 3 years. The evaluator cannot be the person who wrote the programme. AUSTRAC's Transitional Rules 2026 set staggered first-evaluation deadlines. Check austrac.gov.au for your specific deadline.

AML/CTF Staff Training

5 comprehensive modules. Knowledge quiz after each. AUSTRAC-compliant certificate on completion. Records saved to audit trail.

TRAINING PROGRESS

Click Begin to start

Trainee Name (for certificate)

Role

Enter your name and role above, then click Begin Training. Complete all 5 modules to receive your AUSTRAC-compliant training certificate.

CERTIFICATE OF COMPLETION

LUMIERE AUSTRAC COMPLIANCE PLATFORM · TRANCHE 2

This certifies that the following person has successfully completed the Lumiere AML/CTF Staff Training Programme, covering all mandatory AUSTRAC Tranche 2 obligations for Australian real estate agents.

Modules: (1) What is AML/CTF · (2) CDD in Practice · (3) Red Flags · (4) SMR & Tipping-Off · (5) Programme, Records & Annual Obligations

ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING AMENDMENT ACT 2024

Training Register

Retain for 7 years. All certificates recorded here.

No completions recorded yet.

Field Tool — Mobile Optimised

Use this at listing appointments and inspections. Captures the essential CDD data, runs an instant risk check, and saves to your audit trail. Optimised for phone screens.

Step 1 — Client Details

Client Full Name

Phone Number

Property

Client Type

Step 2 — Identity Documents

Record the identity documents sighted. 100 points required.

Primary ID

Secondary ID

Verification Method

Step 3 — Quick Risk Check

Flag any concerns. Be honest — better to note and clear than to miss.

Reluctant to provide ID Overseas funds / international buyer Company or trust purchaser Cash or unusual payment method Third party directing transaction Possible PEP (government official / politician)

Quick CDD Result