The market rushed into providing AML software.AMLHQ was built for what comes next
The Deadline Has Passed.Now Compliance Has to Work.
AMLHQ was built specifically for the real estate industry — around the practical realities of vendors, buyers, property transactions, staff, risk and ongoing compliance. More importantly, it was built around what AUSTRAC expects after implementation: effective processes, clear records, ongoing oversight and evidence that your AML/CTF framework is actually working.
So, what does AUSTRAC really require from a real estate agency — and how does AMLHQ deliver it?
Who is actually making the compliance decisions?
Software can identify a red flag — but it cannot take responsibility for the decision that follows. Complex trusts, beneficial ownership, PEPs, unusual transactions, questionable source of funds and potential Suspicious Matter Reports all require informed human judgement. Who is reviewing those matters, making the call and documenting why in your agency today?
Who stands behind your AML framework when AUSTRAC asks questions?
Your Compliance Officer is more than a name on your AML program. They need the authority, knowledge and capacity to oversee compliance, guide staff, review higher-risk matters, manage escalations and demonstrate that your AML/CTF framework is actually working. For many principals, adding that responsibility to someone already running or selling within the business is a significant ask. When AUSTRAC looks beyond the software, who is making sure your agency can demonstrate that the right processes were followed, the right decisions were made and the evidence is there?
"You didn't become a real estate principal to become a full-time AML Compliance Officer. Our CO Model takes that load off your desk — the platform handles the workflow, a real person handles the judgment."
AML HQ is new, but the problem is new too. The market rushed into software. AML HQ was built for what comes next: managed compliance, real oversight and evidence that can stand up when reviewed.
The honest way to find out where you actually stand takes two minutes, not a sales call.
Take the 2-Minute Exposure Check →More Than Software
More Than an AML Platform — A Compliance Framework for Real Estate Agencies
Buying AML software is not the same as being compliant. Your agency still needs the right decisions, evidence, training, reporting and oversight when files get complex. Trusts, companies, PEP alerts, red flags and rushed listings are where mistakes happen. AUSTRAC is far more interested in what your agency can demonstrate it is doing than what a policy document says you plan to do — compliance doesn't live in a PDF, it lives in how your team works every day. Our different approach gives principals a real AML compliance officer and the framework and support software alone cannot provide.
AML HQ gives real estate principals a smarter way to manage know your customer checks and full AML compliance — with four flexible models, cost-neutral pathways and a framework built around Tranche 2 requirements. We are your AML Head Quarters: not rushed to market, not generic software, but a purpose-built compliance solution.
Four flexible models
Solo, CO, CFO and Hybrid — built around how your agency actually operates, not a one-size-fits-all subscription.
Cost-neutral pathways
Fold your compliance cost into the admin and listing fees you already charge across vendor contracts — no new cost to pass on. The CFO model can also offset compliance costs entirely through its own finance income.
Built for Tranche 2
Purpose-built around AUSTRAC's real estate reforms — not retrofitted generic software.
"We Already Chose an AML Provider. So Why Look Again?"
Fair question. Before 1 July, the industry was moving at roughly the speed of a clearance sale. Agencies had a deadline, providers had software, and decisions had to be made. Now there's time to ask the more important question: are you confident your software provides the right level of protection and that correct processes and decisions are being made?
WHY YOU DIDN'T SEE US THEN
The market was solving for 1 July. We were building for what came after it.
Most agencies made their AML decision under deadline pressure — whether through a formal tender, a franchise recommendation, a group-wide rollout, or simply by choosing the best available option at the time.
AMLHQ deliberately entered the market differently. Rather than rushing out another software platform, we built an operating AML compliance model around what real estate agencies actually need once compliance becomes business-as-usual: trained Compliance Officer oversight, judgement on complex matters, escalation management, defensible records, staff support and technology working together.
So if AMLHQ wasn't on your original shortlist, there is a simple reason:
We weren't trying to win the pre-1 July software race. We were building for the compliance environment that followed it.
WHY THAT DECISION IS WORTH REVISITING NOW
You may have bought the right solution for the deadline. The question now is whether it is the right solution for your business.
A franchise group or head office recommendation may have been perfectly sensible when hundreds of offices needed something operational before 1 July. But the landscape has changed.
Compliance now lives inside your office. It is your staff following the procedures, your files creating the audit trail, your Compliance Officer making the decisions — and ultimately your business, reputation and livelihood that need protecting. That makes this a very different decision from simply selecting software.
AMLHQ provides an actual compliance program: specialist technology, AI-assisted oversight and an experienced Compliance Officer working together to help manage the framework, review risk and support your agency when judgement is required.
We are not suggesting your existing provider was a bad decision. It may be doing exactly what you need. We are simply suggesting that, now the rush is over, it is worth asking a better question:
"If I were choosing today — knowing what I know now — would I choose the same model?"
And because AMLHQ's ongoing compliance cost can potentially be recovered through the agency's vendor administration fee methodology, comparing a more comprehensive model does not necessarily mean adding another operating expense.
Don't take our word for it. Compare AMLHQ.com.au with your current provider using ChatGPT, Claude, Gemini or your preferred AI platform, and ask which model provides the more comprehensive approach for a real estate agency.
Before 1 July, the question was: "What can we get in place?" After 1 July, the question is: "Who is actually protecting this business?"
"This may be the best time to re-evaluate your compliance choices, given a new platform now exists with a stronger framework built for business and licence protection."
2-Minute Self-Audit
Am I Exposed?
Complete the 10 online interactive questions. 3 minutes. A personalised AML/CTF exposure report will be written to specifically address your risk and concerns, and appear at the top of your screen as a download.
Start below — your answers shape the AI report you receive at the end.
Question 1 of 10
If AUSTRAC looked back at a file from two years ago — found the buyer was connected to laundering — and asked for your file and decision rationale, how would your current model hold up?
Think about a real transaction. Consider the file, the records, and who made the compliance judgments. Select the answer that most honestly reflects where you are.
👇 Please select your answer by clicking on one of the options below to move to the next question.
Four Models. One Clear Path Forward.
Compliance Should Fit Your Business — Not Force Your Business to Fit the Software.
A five-person independent agency does not operate like a 50-office franchise group. And an office that's already invested in an AML SaaS platform shouldn't have to abandon that investment to get genuine compliance certainty.
AMLHQ took a different approach.
Our four subscription models were developed by Certified Business Advisors and real estate industry experts. Whether you're starting fresh, already have a platform in place, or want to build a finance revenue stream, there's a model that bridges where you are today to where you need to be tomorrow — without forced migration or operational disruption.
And the advisory element matters.
AML compliance touches staff, systems, risk, management, client experience and ultimately profitability. That means your Compliance Officer needs to understand more than a checklist. Through AMLHQ, the CO is supported with business coaching and advisory expertise that can assist your agency with operational decisions, process improvement and growth.
So you're not simply subscribing to compliance software. You're choosing the level of compliance, oversight and business support that best fits where your agency is today — and the path that gets you where you want to go next.
For sole agents and small operators who want a real, structured AML/CTF compliance framework — not a generic tick-box. You manage your own compliance with the confidence of a purpose-built platform behind you.
- Full AML/CTF program framework built in
- GreenID digital identity verification for buyers & vendors
- CDD (Know Your Customer) guidance for complex entities
- SMR & TTR tracking and deadline management
- AI-assisted risk assessment tools
- Annual compliance report generation
- Staff training register & reminders
- AUSTRAC audit-ready documentation
A qualified, dedicated Compliance Officer is assigned to your agency — managing your AML program, monitoring transactions, lodging reports, and keeping you audit-ready at all times. Real people. Real accountability.
- Everything in the Solo Platform, plus:
- Dedicated assigned Compliance Officer (CO)
- CO manages all SMR & TTR lodgements
- Ongoing transaction monitoring — human-led
- Quarterly compliance reviews & reporting
- Staff training delivery & compliance culture
- Direct CO contact — no helpdesk tickets
- Full AUSTRAC audit representation support
Already invested in AML SaaS? Keep it. Add a qualified Compliance Officer to provide the expert oversight layer your platform alone can't deliver. Test the AMLHQ model without migration risk — upgrade to full SENTINEL anytime with zero data loss.
- Keep your existing AML/VOI platform
- Add dedicated Compliance Officer layer
- CO handles SMR, TTR & all reporting
- Risk mitigation without platform change
- Seamless data migration pathway to SENTINEL
- Cost recovery via compliance admin fees
- AUSTRAC audit-ready support
The only model on the market that turns your mandatory compliance cost into a commercial advantage. An embedded, licensed CFO handles full AML compliance AND builds a finance arm inside your agency — generating income that offsets and then exceeds the cost of compliance.
- Everything in the CO Model, plus:
- Licensed Finance Manager embedded in your agency
- In-house mortgage broking revenue stream
- Finance commission: ~$209,817 pa potential
- Saleable loan trail book asset built over time
- Additional property listing referrals
- 100% database protection — stays yours always
- Indicative 5-yr finance arm value: $953,452+
Which Model Is Right for You?
Your compliance model depends on three things: what you have today, where you want to go, and how you want to get there. Here's how to choose.
Already Using an AML Platform?
You've invested in SaaS software — identity verification, CDD, transaction recording. Good. But where's your independent Compliance Officer judgment layer? Where's your audit-ready documentation?
The Answer: Hybrid Model
- ✓ Keep your platform
- ✓ Add professional CO oversight
- ✓ Migrate to SENTINEL anytime
- ✓ Zero platform disruption
Starting From Scratch?
You don't have an AML platform yet. You need a complete, defensible solution from day one — platform, Compliance Officer, and audit-ready infrastructure.
The Answer: CO or CFO Model
- ✓ Full AMLHQ SENTINEL platform
- ✓ Dedicated Compliance Officer
- ✓ CFO builds finance revenue stream
- ✓ Complete compliance certainty
Multi-Office or Franchise Group?
Multiple locations need coordinated compliance governance from the top. Systemic issues across your network require centralized oversight, strategic control, and unified reporting to protect your entire enterprise.
The Answer: Group-Wide Compliance Management
- ✓ Full overview of all offices — group-wide
- ✓ Direct management of compliance issues from the top, to mitigate any systemic issues
- ✓ Robust group-wide compliance protection, all in one place
- ✓ Ability to use the full and Hybrid SENTINEL plus the reporting portal for offices who remain "stand-alone"
The AMLHQ Model Options
Each model is designed for a different agency structure. Choose based on your current setup and business model — not as steps in a progression. Many agencies use Solo, Hybrid or CO independently. Others already have finance solutions in place.
Solo
Start here if you want to self-manage compliance on a structured platform.
Hybrid
Already have SaaS? Use Hybrid to add CO expertise without migration.
CO
Full AMLHQ platform with dedicated Compliance Officer oversight.
CFO
CO + in-house finance revenue stream that offsets compliance cost.
SENTINEL Platform — Enterprise-Grade AML Technology
SENTINEL is built on enterprise-grade infrastructure with AI-assisted compliance analysis, integrated identity verification, and real-time anomaly detection. A purpose-built platform for AUSTRAC Tranche 2 real estate compliance.
Identity Verification & VOI
- GreenID Integration: Integrated identity verification and verification of identity (VOI) directly within SENTINEL
- Mobile-First Verification: Buyers and vendors complete identity verification on their phone via SENTINEL app in seconds — no separate app downloads needed
- SMS/Email Triggers: Agents trigger verification checks directly via SMS or email — instant, frictionless capture
- Real-Time Verification: Results returned instantly with colour-coded compliance status
Know Your Business (KYB) — Expert CO Analysis
- Direct ASIC & Corporate Register Verification: AMLHQ Compliance Officers conduct direct verification checks against ASIC, ASX, and corporate registers for all entities
- Trust Deed Analysis: Expert review of trust deeds to identify beneficial owners, trustees, and control structures — not automated, expert judgment
- Beneficial Ownership Mapping: COs manually map beneficial owners across corporate structures, overseas entities, and family trusts — identifies ultimate beneficial owners (UBOs)
- Disqualified Director Screening: ASIC disqualified persons registry checks for all directors and beneficial owners
- Lower Cost Than Automated APIs: Expert analysis from experienced COs at a fraction of third-party verification service costs
PEP & Sanctions Screening
- Automated PEP Checks: Real-time screening against Politically Exposed Person (PEP) databases
- Sanctions List Matching: Cross-referenced against international sanctions lists and AUSTRAC watchlists
- Instant Alerts: Automatic escalation of matches to Compliance Officer and transaction flags
- Enhanced Due Diligence Triggers: Automatic escalation workflow for further investigation
AI-Assisted Compliance Analysis
- Anomaly Detection: AI instantly detects unusual transaction patterns, suspicious source of funds, and risk indicators
- Risk Assessment: AI-assisted risk scoring based on transaction context, customer profile, and AUSTRAC risk indicators
- Human-in-the-Loop: AI flags for expert CO review — not automated decisions, expert judgment
- Continuous Learning: System learns from CO decisions to improve pattern recognition
Agent Experience — Speed & Simplicity
SENTINEL is built for real estate agents, not compliance specialists. Agents work directly in the platform with:
- ✓ Colour-Coded Status: Green (compliant) to red (escalation required) — no compliance jargon needed
- ✓ One-Click Verification: Single button trigger for buyers/vendors to complete identity verification on their phone
- ✓ Instant Results: Verification completed in seconds, not days — stays within transaction timeline
- ✓ Mobile-First Design: Native SENTINEL app for iOS and Android — agents and customers work anywhere
For Compliance Officers managing oversight:
- ✓ Real-Time Alerts: Instant notification of high-risk transactions, PEP hits, and anomalies
- ✓ Transaction Monitoring Dashboard: Monitor all agency transactions, flag unusual activity, document decisions
- ✓ Audit Trail: Every action timestamped and immutable — regulatory-ready documentation
- ✓ Automated Reporting: SMR, TTR, and annual compliance reports generated automatically
Audit-Ready Compliance Documentation
- Time-Stamped Audit Trail: Every transaction, decision, and action recorded with timestamp and user — AUSTRAC audit-ready
- Immutable Records: Audit logs cannot be altered or deleted — compliance with AML/CTF Act record-keeping requirements
- Suspicious Matter Report (SMR) Management: Automatic SMR tracking, escalation workflow, and AUSTRAC lodgement documentation
- Reporting Portal: Real-time dashboard for SMR, TTR (Threshold Transaction Report), and compliance metrics
Enterprise Security & Compliance
- SOC 2 Type II Certified Infrastructure: Built on Vercel, Supabase (Sydney-based), and Cloudflare — independent security audits
- AES-256 Encryption: All data encrypted at rest and in transit using TLS 1.3 — financial-grade security
- 7-Year Data Retention: Compliant with AML/CTF Act record-keeping requirements — automatically managed
- Role-Based Access Control: Granular permissions for agents, managers, and compliance officers — data isolation
AML Cost Recovery — Business Strategy
Before Price Becomes a Factor —
Understand How to Remove It as One.
Every real estate principal faces the same question when evaluating AML/CTF compliance: what is this going to cost my business? The answer may surprise you — because the cost can be passed to the vendor, legally and transparently, as a standard administration fee on the listing contract. This is not unusual. Every professional service business builds compliance cost into its fee structure. Real estate is no different.
The Insight
Once Cost Is Off the Table — What Actually Matters?
If you can pass the cost through to the vendor — which you can — then price is no longer a differentiating factor between AML providers. Every platform becomes "affordable." So the real question becomes:
Which AML/CTF provider actually protects your licence, survives an AUSTRAC audit, and delivers a complete, defensible compliance framework?
The answer to that question is what should drive your decision — not the monthly fee, and not a slick marketing campaign selling software tools to meet a fast approaching critical deadline. A cheap platform that leaves you exposed to a $33 million penalty or licence suspension is not cost-effective at any price.
The Challenge
Don't Take Our Word For It.
We're confident enough in our proposition to say this directly: compare us online. Open any AI tool — Claude, ChatGPT, Gemini — and ask it to compare AMLHQ.com.au, PEXA Clear, AMLHUB, and First AML on completeness of compliance coverage, franchise network governance, security certifications, and human oversight. Then make your decision on the facts.
When Evaluating Any AML/CTF Provider — Ask These Questions
🔐 Compliance Completeness
- › Do they provide the written AML/CTF program?
- › Is there a named, qualified Compliance Officer?
- › Who authors and lodges the annual AUSTRAC report?
- › Who manages SMR lodgements — 3 business days, or 24 hours for terrorism financing?
🏢 Audit Survivability
- › Can they represent you if AUSTRAC audits?
- › Is your data stored in Australia for 7 years?
- › Are records truly immutable and timestamped?
- › Has the program been independently evaluated?
💼 Commercial Value
- › Can the cost be recovered through vendor fees?
- › Does it generate revenue — not just manage cost?
- › Is there a lock-in contract or exit penalty?
- › What is the true total cost — not just the subscription?
What does AML HQ actually cost your agency?
Net cost: zero.
AML HQ offers three compliance models but here is the part no other provider offers or explains:
Example: $350 subscription ÷ 3 transactions = $117 per transaction
A small, transparent addition to an existing line item — standard industry practice
Net cost to your agency: $0. Full, defensible, AUSTRAC-ready compliance — at zero net expense.
This is the AML HQ Zero Net Cost Model — a practical business methodology promoted and guided by our certified Business Advisors. Many businesses routinely pass on compliance and operational costs through admin fees, and AML HQ makes this straightforward for real estate agencies by showing you exactly how to apply it to your AML subscription. Software-only solutions charge $6 to $399 per month and rarely explain how to offset that cost. When you remove price from the equation using vendor admin fee recovery, the comparison becomes about what you actually get — and on that measure, AML HQ delivers the most complete AUSTRAC-ready program in the market.
Book a strategy call to see your zero-cost modelThe Sentinel Platform
Enterprise-Grade Technology. In Your Pocket.
The AML HQ Compliance Portal is a purpose-built, high-security platform that automates the workflow of AML compliance — so your team focuses on selling, while the system handles the documentation, deadlines, and reporting.
5 Role-Based Portals
Separate, secure logins for Agents, Compliance Officers, Principals, Administrators and AML HQ Super Admin — each seeing only what they need.
AI-Assisted Risk Assessment
Built-in AI analysis assists Compliance Officers with transaction risk assessment, SMR drafting and pattern recognition — reducing manual burden significantly.
Automated AUSTRAC Reporting
SMR and TTR deadline tracking, annual compliance report generation, and full immutable audit trail — all automated, all AUSTRAC-ready.
GreenID — Document Verification & Identity Confirmation
AML HQ integrates GreenID (by GBG/Equifax) — Australia's largest approved Gateway Service Provider for the Federal Government's Document Verification Service (DVS). GreenID verifies Driver's Licences, Passports, Medicare Cards, Australian Visas, Electoral Roll and more — with biometric liveness detection, ISO 27001 certification and a 99.99% uptime SLA. Fast, reliable identity verification for every transaction.
Expert KYB Analysis — Trust Deeds & Corporate Structures
For complex vendors, purchasers, trust structures, corporate entities and offshore parties — AMLHQ's Compliance Officers conduct expert analysis. COs review trust deeds, verify beneficial owners against ASIC records, identify trustees and control structures, and assess structural risk. This is genuine Know Your Business analysis — the kind of deep structural expertise that separates real compliance from software-only solutions. Lower cost than automated KYB APIs, better judgment than algorithms.
PEP, Sanctions & Adverse Media Screening
Every principal, vendor and purchaser is screened against Politically Exposed Persons (PEP) lists, international sanctions databases and adverse media sources. SENTINEL's automated screening engine continuously monitors all parties beyond initial onboarding, throughout the transaction lifecycle, ensuring your agency remains protected and compliant.
How a file moves through Sentinel
Compliance gated at every stage — not a checkbox at the end
Hosted on infrastructure independently certified to:
Enterprise-Grade Protection
Enterprise-Grade Security. Australian-First.
AML HQ's AML Compliance Portal is built on an enterprise security stack, informed by the standards used across Australia's financial services sector — with every byte of your data stored on Australian soil. We don't have the resources of a major bank, but security has been built in as a genuine priority from day one, not an afterthought.
Complete Security Certification Stack
Audit Trail — Every Action. Every Time.
Every login, compliance decision, document upload, SMR lodgement and status change is recorded with the user's name, timestamp and IP address — creating an immutable audit trail that AUSTRAC can inspect at any time. This is not optional. This is the law — and we've built it in from day one.
99.99% Uptime SLA — Always Available.
Compliance deadlines don't move. Our platform is hosted on Vercel's enterprise infrastructure with a 99.99% uptime SLA and automatic failover — ensuring your team can access compliance workflows whenever needed, especially in the critical days before settlement.
Multi-Office. Franchise Networks. Large Groups.
What AUSTRAC Actually Demands from Groups & Franchises.
A cloud-based software tool cannot solve a group compliance problem. AUSTRAC's AML/CTF Rules 2025 impose specific governance and uniformity obligations on franchise networks and reporting groups — obligations that require embedded human expertise, not just software access. To our knowledge, no other AML compliance provider in this market offers whole-of-group oversight that works even when individual offices run different point-solution software — this is a genuinely separate benefit, on top of whatever each office already has in place.
A tool without a team
- ✗ No embedded compliance officer to enforce group-wide consistency
- ✗ Individual offices can diverge — AUSTRAC won't accept "the software let them"
- ✗ No per-transaction pricing advantage when you have 20+ offices
- ✗ No active governance — passive access is a liability, not a defence
- ✗ No support for the independent evaluation requirement
- ✗ Statutory liability remains with you — the software takes no responsibility
"In a group/franchise, the real setup risk is uneven execution between offices — and regulators tend to notice. The documented position is that obligations don't 'scale down'; expectations around control, documentation, consistency, and governance discipline only scale up."
— AML HQ AML/CTF Master Guide for Groups & Franchises (2026)
The People Behind AML HQ
Finance. Real Estate. Certified Business Advisory.
A New Evolution in Compliance.
AML HQ brings together a finance veteran, a real estate professional and trainer, and a certified professional business advisor — combining three disciplines to deliver a compliance model that is commercially intelligent, practically grounded, and genuinely defensible.
Phil is a finance industry veteran and the visionary behind AML HQ. With decades of experience in regulated financial services, Phil identified the critical gap in the Australian real estate market — agencies that needed genuinely defensible AML compliance, not a software tick. He established the Emerald Group Holdings network of affiliated businesses and developed AML HQ through Business Advice Agency Pty Ltd to solve that problem commercially.
Noel is a real estate professional and certified professional business advisor who oversees the strategic and operational integrity of every AML HQ program. His dual expertise in real estate operations and business advisory ensures that each agency's compliance framework is commercially structured, legally sound, and built to scale.
Trish is a seasoned real estate professional and trainer who brings deep industry understanding to AML HQ's operational delivery. She knows how agencies work from the inside — which means the compliance frameworks she implements are practical, agent-friendly, and built for real-world adoption, not just documentation.
Part of the Emerald Group Holdings Network
AML HQ is operated by Business Advice Agency Pty Ltd and forms part of the Emerald Group Holdings network of affiliated Australian businesses under common ownership. Each affiliated business operates through its relevant legal entity, licences and regulatory framework.
THE AML HQ DIFFERENCE
Why AML HQ Is Different From Every Other Option
AML HQ is not another software tool dressed up as a compliance solution. We are compliance professionals with decades of hands-on experience in regulated finance, supported by technology and a human framework built to withstand real-world scrutiny. We do not view AML as a box-ticking burden. We view it as a critical business function that, when structured properly, can protect the principal, strengthen the agency and support sustainable growth. AML HQ was not founded by software developers or back-room compliance technicians. It was built on business best practice and certified professional advisory methodologies to deliver protection, structure and commercial strength.
Our clients don't just have a tick in a box. They have a genuine, defensible AML/CTF framework — one that would hold up to AUSTRAC scrutiny on audit day, because that is precisely what it was built for.
Book Your Strategy CallAML HQ is new, but the problem is new too. The market rushed into software. AML HQ was built for what comes next: managed compliance, real oversight and evidence that can stand up when reviewed.
Finance-Industry Pedigree
Our team has operated in regulated finance — where AML compliance is a daily reality, not a Tranche-2 addition. We bring 20 years of that discipline to your agency.
Human Accountability — Not Just Software
Software can collect data. It cannot exercise judgment. Under our CO and CFO models, every client has a named, qualified Compliance Officer who is personally accountable for the program. Solo is our structured self-managed option, for agencies who want to run their own compliance with a proper framework behind them, without a dedicated officer.
The Only Revenue-Generating Model
Our CFO Model is the only AML compliance structure on the Australian market that converts a mandatory cost into a new income stream — under your brand, your database, your asset.
Middle-Market Pricing — No Compromise
Not the cheapest. Not the most expensive. Positioned deliberately in the middle — delivering enterprise-grade defensibility at a price that makes commercial sense for any serious agency.
Under the CFO Model — Your Database. Your Asset. Always.
Under the CFO Model, your client data never flows to an external broker. It stays in your system, under your control, building enterprise value — not someone else's loan book.
Audit-Ready. From Day One.
Our programs are built to survive AUSTRAC's mandatory three-yearly independent audit — not just the enrolment process. Defensible documentation from your first day as a client.
The standard that matters
Remove the price. See what you're actually getting.
AUSTRAC will not ask what you paid for compliance. They will ask what you have. Here are the five requirements every real estate agency must be able to demonstrate — and how the market stacks up when price is taken out of the conversation.
← Swipe sideways to see the full comparison →
| What AUSTRAC requires | AML HQ Full Program |
PEXA Clear | First AML | AML Hub | AML Assured |
|---|---|---|---|---|---|
| Written AML/CTF ProgramTailored to your agency, approved by senior management | ✓ Done for you | ~ Template only | ~ Template only | ~ Template only | ~ Wizard-generated |
| Named Compliance OfficerA real, accountable person — named with AUSTRAC | ✓ Embedded human CO | ✗ Software only | ✗ Software only | ✗ Software only | ✗ Software only |
| Agency Risk AssessmentSpecific to your clients, services and geography | ✓ Custom built | ~ Transaction & property risk model | ~ Generic framework | ~ Generic framework | ~ AI-generated |
| Staff Training + RecordsDelivered and documented — AUSTRAC can ask for proof | ✓ Annual, recorded | ~ Via training partner | ✗ Not included | ~ Self-serve modules | ~ Role-based modules |
| Independent Program ReviewRequired by law at least every three years | ✓ Coordinated with a genuinely independent third-party evaluator | ✗ Not included | ✗ Not included | ✗ Not included | ✗ Not included |
| Zero Net Cost OptionVendor admin fee recovery — full cost neutralisation | ✓ Promoted & guided by AML HQ | ✗ Not promoted | ✗ Not promoted | ✗ Not promoted | ✗ Not promoted |
| Price removed. What are you left with? | Full defensible compliance | ID check only | ID + templates | ID + templates | ID + program wizard |
✦ Competitor information based on publicly available product descriptions at time of publication. Always verify current offerings directly with each provider.
Want the full, detailed breakdown against a specific provider?
Common Questions
Frequently Asked Questions
Take The First Step
Book Your Strategy Call
In a single confidential session, we'll review your current compliance position, identify any critical gaps, and outline exactly what a defensible AML/CTF program — and the right model — looks like for your specific agency. No obligation. No pressure.
7 / 3972 Pacific Highway, Loganholme QLD 4129 · admin@amlhq.com.au · 1300 330 644
Entirely Optional
Beyond Compliance: An Optional Way to Grow
Everything above this point is genuinely all you need for AUSTRAC compliance — the Solo and CO models are complete, standalone solutions on their own. What follows is a separate, entirely optional path for agencies that don't already have their own finance arm and are interested in building one. If your agency already has an established finance or lending arrangement, this simply won't be relevant to you — and that's completely fine.
The CFO Model — Explained
Turn Compliance Into a Commercial Asset
For agencies without an existing finance arm, AML HQ's Certified Professional Business Advisors (CPBA) — built for business growth, and led by finance experts who have managed AML compliance since 2008 — offer an optional CFO Model. It places a licensed Finance Manager (AML Ready) inside your agency, handling your AML/CTF compliance obligations while building a finance revenue line that belongs entirely to you.
Your client database remains 100% yours. Contractually. Always. Compare that to referring clients to an external mortgage broker: every conversation builds their database, not yours — so when that client is ready to buy or sell again, there's no structural reason they come back through your agency rather than wherever the broker sends them. Under the CFO Model, that same client relationship builds your asset instead, and over time the finance arm becomes a saleable asset that adds directly to the enterprise value of your business.
💰 Indicative CFO Model Returns
Check out the CFO Calculator below to see the potential benefits for your office.
Figures are indicative based on industry-standard metrics. Individual results will vary. See full calculator below.
The CFO model works differently within each office. Growth results depend upon agency engagement and motivation.
Not Another Desk-Sharing Arrangement
Genuinely Different From Legacy Broker-in-Office Models
If you've seen an embedded finance arrangement before — a broker given a desk in the office in exchange for referral fees — this isn't that. Our founder built one of these legacy models 17 years ago and knows firsthand exactly what they do, and don't, deliver. The CFO Model is built differently: genuine commitment to your agency rather than a desk-sharing arrangement, contractual data safety for your client database, ongoing Professional Business Advisory and business coaching, and an experienced mortgage broker specifically trained in Tranche 2 AML/CTF compliance — a natural extension of the Tranche 1 finance-industry AML compliance the finance sector has operated under for years. The whole structure is built around Business Advisory methodologies designed to grow listings and income for every party involved, not to generate referral fees for someone else's business.
The CFO Offset Calculator
See What Your Agency Could Earn
If the CFO Model above is relevant to your agency, enter your profile below to see how it could convert your AML compliance cost into another commercial income stream.
This calculator is a commercial illustration tool using industry-standard metrics. Results are indicative only. Finance-arm values use a trail multiple of 2.5× annual trail plus 3× EBITDA proxy, with 18% annual trail run-off. AML HQ is operated by Business Advice Agency Pty Ltd and forms part of the Emerald Group Holdings network. Any credit assistance is provided separately by EZFinance Pty Ltd, Australian Credit Licence 392611.
The Market Has Turned
Fewer Sales. Harder Sales. A Tougher Market.
Conditions have shifted toward a buyer's market in much of the country — fewer transactions, longer days on market, and more competition for the listings that do come up. Compliance was never going to be the only thing your office needed to rethink this year. The harder question underneath it is simple: what is your agency actually doing to protect profitability as the market gets tougher?
A Word of Caution, From Us
Many offices have tried a broker-referral arrangement before — a desk in the corner, a handshake deal, a database quietly leaking out the back door with nothing much coming back the other way. If that's been your experience, you'd be right to be sceptical of anything that sounds similar. What follows genuinely isn't that, and we'd rather earn that distinction than just assert it.
Inside the CFO Model
Know Where You Stand
A structured listing-intelligence model built into the CFO Model — designed by Certified Professional Business Advisors and delivered by Certified Professional Business Advisors, not a loose referral arrangement dressed up with a new name.
THE HIDDEN PROBLEM
Most agencies aren't short of contacts — they're short of timing intelligence. Your database likely already contains future sellers, landlords, investors and upgraders who won't reveal themselves through a normal sales conversation. Many future listings begin as finance, timing, equity or next-move conversations, long before they ever become an appraisal request.
WHY IT'S DIFFERENT
A legacy broker relationship starts with one narrow, reactive question: "can we send this buyer to a broker for a loan?" Know Where You Stand starts with a better one: can the right conversation help the agency identify intent, timing and opportunity earlier — with structure, reporting and follow-up discipline the principal can actually see?
150+
Lenders and funders — supports investors, self-employed and complex borrowers
National
Capability across multiple markets, not one local broker relationship
CPBA
Built and delivered by Certified Professional Business Advisors — not generic brokers
Selected
Brokers upskilled in agency workflows and listing-sourcing intelligence, not just loans
"In this market, it helps to know where you stand before you make your next move." That's the client-facing message — useful to the client, natural for the agent, and commercially meaningful for the agency. It doesn't sound like a finance pitch, and it doesn't feel like a referral.
A short discussion. High-level overview. No obligation.
Ask for a Private Walkthrough of the Model →AMLHQ Resources
AML Compliance Guides for Real Estate
AML Compliance FAQ — Australian Real Estate Agencies
15 plain-English answers to the most important questions about AML/CTF compliance obligations — AUSTRAC deadlines, costs, Compliance Officers, GreenID, SMRs, TTRs and franchise group requirements.
Read the Full Guide →Compare AML Compliance Providers — Australia 2026
How does AMLHQ compare to PEXA Clear, First AML, AMLHUB and AML Assured? An honest, sourced comparison across the five criteria AUSTRAC actually measures.
See the Comparison →Blog & Resources — AUSTRAC Guidance & AML Updates
AMLHQ's blog covers AUSTRAC Tranche 2 updates, compliance tips for real estate agents, and practical guidance on running an AML/CTF program in a real estate agency.
Visit the Blog →Join The AML HQ Network
Broker & CO Opportunities
Are you a finance professional, compliance officer, or mortgage broker looking for a structured, rewarding opportunity in the growing AML compliance space?
AML HQ is actively building its national network of Compliance Officers (COs) and Compliance & Finance Officers (CFOs). As a AML HQ CO or CFO, you'll be embedded with real estate agencies — delivering compliance programs, building finance income streams, and growing a recurring revenue book under a proven, supported framework.
Who We're Looking For
Compliance Officer (CO)
Background in compliance, financial services, legal or business advisory. Comfortable managing AML programs, documentation and reporting. Full training provided.
Compliance & Finance Officer (CFO)
Licensed mortgage broker or finance professional looking to add compliance income to your existing practice. Embedded agency model with full AML HQ support.
Referral Partners
Real estate trainers, business coaches, franchise consultants or industry professionals who work with agency principals. Generous referral structure available.
To find out more, email admin@amlhq.com.au with the subject line "CO/CFO Opportunity" and a brief note about your background.