Requirement / Feature Property360 Agency AMLHUB First AML PEXA AML AML Assured
AUSTRAC Requirement 1 — Written AML/CTF Program
Written program — tailored to agency ✓ Included in setup Yes — via advisory service Partial — template Template provided
Program maintenance and updates ✓ Included Available — extra cost tier Not specified Extra cost
AUSTRAC Requirement 2 — Customer Due Diligence (CDD)
Digital identity verification (VOI) ✓ GreenID (~$5.90/check) Third-party
Risk scoring / flag system ✓ Green / amber / red Basic Basic
AI analysis for CO review ✓ Claude-powered (CO only)
AUSTRAC Requirement 3 — Ongoing Monitoring
Named embedded Compliance Officer ✓ CO & CFO models Advisory support — not embedded ✕ Software only ✕ Software only Advisory add-on
Compliance hold / escalation workflow ✓ SENTINEL built-in Basic Basic
AUSTRAC Requirement 4 — Reporting (TTR / SMR)
TTR alerts ($10,000+ cash) ✓ Automated alerts Basic
SMR guidance and lodgement support ✓ CO-managed Available — expert support tier Self-service Advisory
AUSTRAC Requirement 5 — Record Keeping (7 Years)
7-year compliant record storage ✓ Australian hosted
Differentiators — Zero Net Cost & Platform
Finance income stream (CFO Model) ✓ Unique — CFO Model
Potential zero-net-cost compliance ✓ All three models
How zero-net-cost works CFO Model: covered by finance income. Solo & CO Models: covered via vendor admin fee recovery — see Cost Recovery on the main site. No equivalent mechanism offered
Mobile-first field app (SENTINEL) ✓ Phone & desktop ✓ Mobile app available Web only Web only Web only
Real estate sector specialisation ✓ Real estate only ✓ Real estate focused Multi-sector ✓ Real estate Multi-sector
Starting monthly price (ex. setup) $350+GST/month ~$399+/month Contact for pricing Contact for pricing ~$300+/month

The 5 AUSTRAC Requirements

What Every Real Estate Agency Must Have

From 1 July 2026, every Australian real estate agency assisting with property sales is a Reporting Entity under the AML/CTF Act 2006 (Cth). These five obligations are non-negotiable.

01

Written AML/CTF Program

A tailored written program identifying your agency's money laundering risks and how you address them.

02

Customer Due Diligence

Verify the identity of every buyer and seller before providing any designated service.

03

Ongoing Monitoring

Continuously monitor client transactions and relationships for suspicious activity or change in risk profile.

04

Regulatory Reporting

Lodge Threshold Transaction Reports (TTR) and Suspicious Matter Reports (SMR) to AUSTRAC as required.

05

Record Keeping (7 Years)

Maintain and store all AML/CTF records for a minimum of seven years and produce them on AUSTRAC request.

Zero-Net-Cost Methodology

Property360 is the only AML compliance provider in Australia that can make your compliance cost revenue-neutral. The CFO Model isn't a theoretical concept — it's a structured methodology delivered through licensed entities.

1

Finance Officer Activates Your Database

Your past clients, current listings, and active buyers are all finance events. The embedded FO identifies and engages each opportunity.

2

Settlements Generate Commission

Each settled finance client generates upfront commissions and ongoing trail income via EZFinance (ACL 392611).

3

Broker Referrals Become Listings

The finance network refers vendor and buyer listings back to your agency — new stock at zero marketing cost.

4

Compliance Cost Absorbed

At 4 settlements per month, the combined income covers — or exceeds — your $495+GST/month compliance subscription.

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