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AML/CTF Reform: Designated services decision trees

Disclaimer: The content on this website is general and is not legal advice. Before you make a decision or take a particular action based on the content on this website, you should check its accuracy, completeness, currency and relevance for your purposes. You may wish to seek independent professional advice.


 

AUSTRAC released their reform guidance in October 2025 and it was comprehensive but dense.

We've translated the information into practical decision trees so you know when and what is a designated service and requires AML/CTF compliance.

 

Are you regulated?

Real estate services (Reform)

Use the linked decision trees below to find out if you're offering a designated service and will be regulated by AUSTRAC.

Item 1: Seller's agent - brokering the sale, purchase or transfer of real estate

View decision tree

Decision tree

Item 1: Buyer's agent - brokering the sale, purchase or transfer of real estate

View decision tree

Item 2: Selling or transferring real estate without an independent real estate agent

View decision tree

 


 

Professional services (Reform)

Use the linked decision trees below to find out if you're offering a designated service and will be regulated by AUSTRAC.

Decision tree

Item 1: Assisting to plan or execute a transaction to buy, sell or transfer real estate

View decision tree

Decision tree

Item 2: Selling, buying or transferring a legal arrangement or body corporate

View decision tree

Decision tree

Item 3: Receiving, holding, controlling or managing a person’s property (assets)

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Decision tree

Item 4: Equity or debt financing for a body corporate or legal arrangement

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Decision tree

Item 5: Selling or transferring a shelf company

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Decision tree

Item 6: Creating or restructuring a body corporate or legal arrangement

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Decision tree

Items 7 & 8: Acting on behalf of a person or as a nominee shareholder in a body corporate or legal arrangement

View decision tree

 

Decision tree

Item 9: Providing a registered office address or principal place of business

View decision tree

 


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