Counter Terrorism Courses and Financing Compliance for Real Estate Professionals
Counter terrorism financing is now a direct compliance issue for many Australian real estate businesses.
From 1 July 2026, Australia's expanded anti-money laundering and counter-terrorism financing regime began applying to newly regulated real estate businesses that provide designated services, including relevant seller's agents, buyer's agents and some property developers.
For property professionals looking for counter terrorism courses, the relevant training is generally part of the broader AML/CTF framework. The objective is not to turn an agent into a counter-terrorism investigator. It is to help staff recognise risk indicators, complete the required customer checks and know when a concern needs to be escalated or reported.
Key Takeaways
Relevant real estate businesses have been subject to AML/CTF obligations since 1 July 2026.
Terrorism financing can involve legitimate as well as criminally derived funds.
Transactions associated with terrorism financing may involve relatively small amounts and can therefore be difficult to distinguish from ordinary activity.
Regulated agencies need risk-based AML/CTF programs, customer due diligence processes and appropriate personnel training.
A suspicious matter relating to terrorism financing must be reported to AUSTRAC within 24 hours of forming the suspicion.
What Is Counter Terrorism Financing?
Counter terrorism financing refers to providing or moving funds that support terrorism or people involved in planning, encouraging or carrying out terrorist activity.
Unlike conventional money laundering, terrorism financing does not always begin with proceeds of crime. Funds may come from legitimate salaries, businesses, donations or other lawful sources before being diverted for an unlawful purpose. AUSTRAC's 2026 assessment notes that domestic terrorism financing often involves small, fragmented amounts, which can make it difficult to identify from financial behaviour alone.
What Is Counter Terrorism Financing Training?
Counter terrorism financing training teaches personnel how to recognise, manage and escalate terrorism-financing risks under the AML/CTF framework.
For frontline real estate staff, appropriate training should explain their role, customer due diligence, relevant risk indicators, internal escalation procedures and suspicious matter reporting.
AUSTRAC's Smart real estate agent's guide to AML/CTF covers these areas through practical scenarios, customer conversations and exercises. AUSTRAC also makes clear that its general training package does not replace an agency's obligation to provide training specific to its own business and ML/TF risks.
What Are Potential AML/CTF Red Flags in Real Estate?
A red flag does not automatically mean that terrorism financing or another crime has occurred. Agencies should consider indicators in context and follow the procedures in their AML/CTF program.
Potential indicator | Why it may require further attention |
Customer cannot reasonably explain their source of funds or wealth | Funding may not match the customer's known circumstances |
Complex or unusual payment arrangements | Additional parties or structures can obscure who controls funds |
Significant use of third-party transfers, offshore institutions or virtual assets | The payment path may require additional risk assessment |
Transaction appears to have no clear economic or legal purpose | Unusual structures may warrant further enquiries |
Customer is reluctant to complete required due diligence | Resistance to identification procedures can be a risk indicator |
Links to higher-risk jurisdictions, sanctions concerns or adverse information | The customer's overall risk level may require enhanced controls |
AUSTRAC advises real estate businesses to assess customers against sector-specific risk factors and indicators, including unexplained wealth, unusual payment arrangements, virtual assets, high-risk jurisdictions and transactions with no apparent economic or legal purpose.
What Do Real Estate Businesses Need to Do?
Regulated agencies need an AML/CTF program that reflects the services they provide and the risks specific to their business.
That includes completing customer due diligence, assigning risk ratings, monitoring changes in customer behaviour or circumstances, applying enhanced controls where required and escalating suspicious activity.
The program must also address personnel responsibilities and training. AUSTRAC specifically requires businesses to plan training when assigning AML/CTF roles.
Where a reporting entity forms a suspicion connected with terrorism financing, the suspicious matter report must reach AUSTRAC within 24 hours. Other suspicious matters generally have a three-business-day reporting timeframe.
Which Counter Terrorism Courses Apply to NSW Real Estate Professionals?
For the 2026/27 NSW CPD year, residential real estate salespeople and buyers agents must complete the compulsory topic Supervision Guidelines and AML CTF in agency practice as part of their required interactive training.
Relevant Class 1 agents have an additional requirement to complete AUSTRAC's Smart real estate agent's guide to AML/CTF. NSW Fair Trading states that this requirement is separate from the compulsory CPD topics delivered by approved providers.
Proxima Academy is listed as a NSW Fair Trading approved provider for the current CPD year.
You can enrol for compulsory CPD topics for 2026/27 or explore Proxima Academy's other real estate training programs.
