Doing AML Personnel Due Diligence on Your Team
Casey Cossu
In short: agencies must verify the identity, qualifications and licensing of every staff member or contractor who performs AML duties — and collect more information where doubts arise. Below is what to collect, plus the free licence registers for every state and territory.
Under the new Anti-Money Laundering (AML) laws which commenced on 1 July 2026, reporting entities are required to carry out due diligence on all staff members and contractors who will perform AML duties as part of their roles.
For a real estate agency, this may include management, sales agents and administration/support staff.
Although the laws don’t prescribe the exact documents or searches needed to satisfy the due diligence requirement, AUSTRAC does provide guidance on what information should be collected from the employee and how to assess their suitability for the role.
The kind of information to collect will depend largely on your agencies’ AML policies and procedures. If your agency has adopted the AUSTRAC recommended policies using the starter kits, then this will involve:
verifying the employee’s identity
verifying their qualifications and licensing
collecting additional information about the employee if there are doubts about their integrity, identity, competence or independence to perform the role (this may include a reference of employment check, adverse media check and obtaining a statutory declaration if there are any self-reporting requirements under your policy).
How Do You Check a Real Estate Licence or Registration?
Each jurisdiction in Australia keeps a public and free register of all real estate agents that are licensed/registered in their jurisdiction.
A search of the relevant register should be undertaken by the person carrying out personnel due diligence (usually the Compliance Officer), to verify that the employee holds the level or category of licensing that they disclose to the agency.
The name or licence number of the individual can be searched. It’s important to ensure that the status of the licence or registration is current and active.
New South Wales
Verify NSW – Property and real estate agents
Victoria
Consumer Affairs Victoria – Public register of estate agents
Queensland
Office of Fair Trading – Fair Trading Licensing Register
South Australia
Consumer and Business Services – Find a Licence Holder
Western Australia
Consumer Protection – Licence and Registration Search
Tasmania
Property Agents Board of Tasmania – Register of Property Agents
Northern Territory
NT Licensing – Public Register
Australian Capital Territory
Access Canberra – Real Estate and Property (public registers linked from this page)
A Few Practical Tips
Don’t rely solely on a copy of the licence or registration. Documents can be easily fabricated, especially with AI. Use the relevant jurisdiction register to verify the information provided by the employee.
Build it into your onboarding procedure. The personnel due diligence process should be built into your onboarding procedure for the agency. This process will need to be carried out for all existing employees and new starters from 1 July. This should be consistent across each part of the business captured by AML laws.
If something doesn’t match, don’t proceed on trust. Clarify before continuing and consider asking the employee to provide a self-reporting statutory declaration.
Why This Matters
Completing personnel due diligence is a statutory requirement under the new AML laws. When it comes time to carry out an independent evaluation of your agency’s compliance with your AML Program and the laws, this will be one of the items of compliance reviewed by the evaluator. To avoid potential breaches and adverse findings, it is important to establish procedures for AML personnel due diligence as part of your normal employee onboarding process. If you’re setting up your agency’s compliance from scratch, see our week one AML/CTF roadmap for where this fits.
Disclaimer
This article is provided for general informational purposes only and does not constitute legal advice. It reflects a general summary of publicly available guidance and is not a comprehensive or authoritative interpretation of the Anti-Money Laundering and Counter-Terrorism Financing Act, associated Rules, or any other legislation. Laws, regulations and regulatory guidance can change, and how they apply will depend on your specific circumstances. Before acting or relying on any information contained in this article, you should seek independent advice tailored to your situation.
