Five AUSTRAC compliance requirements. Five providers. One clear answer. See how AML HQ stacks up against AMLHUB, First AML, PEXA Clear, and AML Assured.
Competitor data is based on publicly available information and AML HQ's assessment as at July 2026. Features may change. Consult each provider directly to verify current offerings.
The AML compliance market is full of noise right now — providers claiming to be "fully done for you" or offering "complete AUSTRAC coverage" with little public detail to substantiate it. For a Principal carrying personal liability, that's a genuinely hard environment to make an informed decision in. AML HQ was built by Certified Business Advisors around a real compliance structure — not just a login screen — and this comparison exists to cut through the noise with sourced, verifiable facts, so you can decide on real information rather than a marketing claim.
| Requirement / Feature | AML HQ | AMLHUB | First AML | PEXA Clear | 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 | |||||
| Franchise/group Head Office oversight | ✓ SENTINEL group portal — works even for offices not on AML HQ | ✕ Not offered | ✕ Guidance only | ✕ Not offered | ✕ |
| Finance income stream (CFO Model) | ✓ Unique — CFO Model turns compliance into a profit centre | ✕ | ✕ | ✕ | ✕ |
| Vendor admin fee recovery guidance | ✓ Actively guided by AML HQ | Available to any agency with any provider — not unique to a specific platform | |||
| How cost-neutrality works | CFO Model: covered and exceeded by finance income — a genuine profit centre. Solo & CO Models: costs can be recovered via vendor admin fee recovery (a general technique available with any provider) — see Cost Recovery on the main site. | Vendor admin fee recovery is a general business practice — ask any provider whether they help you set it up | |||
| Mobile-first field app (SENTINEL) | ✓ Phone & desktop | ✓ Mobile app available | Web only | Web only | Web only |
| Real estate sector specialisation | ✓ Real estate only | Adapted from NZ real estate platform (est. 2018) | Multi-sector | ✓ Real estate | Multi-sector |
| Pricing model | From $350+GST/month + VOI/KYC at cost | $100–$250+GST/month (tiered) + VOI/KYC at cost | Contact for pricing | $40–$65+GST per transaction (no subscription) | ~$300+/month + VOI/KYC at cost |
| Net cost after admin fee recoveryAny agency can apply this with any provider | ✓ Can be $0 — we actively guide the setup | Same mechanism available — ask the provider whether they help you set it up | |||
The 5 AUSTRAC Requirements
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.
A tailored written program identifying your agency's money laundering risks and how you address them.
Verify the identity of every buyer and seller before providing any designated service.
Continuously monitor client transactions and relationships for suspicious activity or change in risk profile.
Lodge Threshold Transaction Reports (TTR) and Suspicious Matter Reports (SMR) to AUSTRAC as required.
Maintain and store all AML/CTF records for a minimum of seven years and produce them on AUSTRAC request.
The CFO Advantage
AML HQ 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.
Your past clients, current listings, and active buyers are all finance events. The embedded FO identifies and engages each opportunity.
Each settled finance client generates upfront commissions and ongoing trail income via EZFinance (ACL 392611).
The finance network refers vendor and buyer listings back to your agency — new stock at zero marketing cost.
At 4 settlements per month, the combined income covers — or exceeds — your $990+GST/month compliance subscription.