The 10‑Day Real Estate Compliance Sprint
The 10‑Day Real Estate Compliance Sprint
New AML/CTF reforms and privacy law updates are raising the bar for Australian real estate agencies. Here’s a practical, small‑team playbook—told through one agency’s sprint—to close compliance gaps fast: map data flows, modernise VOI/KYC, enforce MFA and least‑privilege, and lock in vendor contracts that address AUSTRAC and the Privacy Act. Risk alert: without auditable controls and timely OAIC breach notifications, penalties and enforcement action are real.
1) The Wake‑Up Call: “Document your business or get out”
When a boutique Brisbane agency heard their advisor say, “Document your business or get out,” it finally landed. The Privacy Bill 2024 was accelerating expectations; as of May 2025, stricter privacy handling rules were in play; Queensland’s seller disclosure regime would commence on 1 August 2025; and AML/CTF obligations for certain designated services would ramp up across 2026 (including new rules from 31 March 2026 and obligations applying to some services from 1 July 2026). For property businesses with annual turnover above $3M, Privacy Act compliance isn’t optional—data security is a core legal responsibility.
- Problem: fragmented records, vague VOI/KYC steps, and no proof trail.
- Consequence: reliance on third‑party KYC without assurance; weak access controls; unclear breach response.
- Risk: enforcement action and significant penalties for missing OAIC notifications or failing AUSTRAC expectations.
“We can’t keep asking people to ‘just remember’ the right way. The system has to remember for us.”
2) Problem: Scattered Records, No Single Source of Truth
Client files lived in email threads, a CRM, a property management app, and an admin’s desktop. Staff didn’t know which record was authoritative.
The Fix: One‑Day Data‑Flow Map
- List every system touching personal or property data (CRM, PM, IDV, e‑signature, email, finance).
- Draw flows for collection, use, disclosure, storage, and deletion—note cross‑border transfers.
- Declare a system of record for each data domain (e.g., CRM for vendors/buyers; PM app for tenants).
- Flag gaps: missing retention rules, unsecured spreadsheets, and ad‑hoc exports.
Outcome: a single source of truth and the backbone for an updated privacy policy, Records of Processing, and access permissions.
3) Problem: Fragile Reliance on Third‑Party KYC
The team relied on an IDV vendor and conveyancer checks without formal reliance arrangements or assurance of their controls.
The Fix: AUSTRAC‑Aligned Reliance Framework
- Execute reliance agreements that set who verifies, evidence retained, timeframes, and audit rights.
- Update contracts to reference AUSTRAC expectations and Privacy Act obligations, including secure data handling and breach cooperation.
- Stand up a quarterly “assurance pack” review: sample KYC files, watchlist coverage, failure rates, and control attestations.
- Document a fallback VOI path if reliance breaks (system outage, high‑risk customer, or mismatch).
Result: clear accountability and proof of reasonable reliance—no more hand‑waving.
4) Problem: Out‑of‑Date VOI/KYC Procedures
Agents kept photocopies and ad‑hoc notes; remote workers varied in what they captured, risking inconsistent practices.
The Fix: Risk‑Based VOI with Remote Playbooks
- Use an IDV tool with liveness, document authenticity, and PEP/sanctions checks.
- Score transaction risk (property type, geography, complexity, unusual payment patterns) and escalate enhanced due diligence where needed.
- Standardise evidence retention: what to keep, where to store, and for how long.
- Embed scripts and checklists in the CRM: “collect, verify, record, review, approve.”
Make It Stick for Remote Workers
- Provide a click‑through SOP with screenshots and a 5‑minute micro‑video.
- Require agents to attach IDV reference numbers to the deal record—no number, no progress.
- Add a quality‑assurance spot check: 5% of files sampled weekly.
“If it’s not in the checklist, it didn’t happen.”
5) Problem: Security Gaps—MFA and Least‑Privilege Missing
Shared logins and broad access were common, and de‑provisioning lagged when staff left.
The Fix: Harden Access in 48 Hours
- Enforce SSO + MFA across CRM, PM, email, and file storage; block legacy protocols.
- Apply role‑based access: sales can view, not export; admins can export with approval; finance sees only payment data.
- Reduce admin rights to a break‑glass account with check‑in/out and approval.
- Adopt a password manager and device encryption; require auto‑lock and patching.
- Scope vendor API tokens to least privilege; rotate keys quarterly.
- Centralise logs and alerts for suspicious access or mass downloads.
What Changed for Staff?
Two quick wins: a single MFA prompt via SSO and a ticketed process for elevated data access. Remote workers now follow the same SOP as in‑office staff.
6) Resolution: Auditable Controls and Breach Response
With foundations laid, the agency closed the loop: proving compliance, not just declaring it.
- Audit trail: who verified identity, which checks ran, outcomes, timestamps, and approver.
- Change management: documented updates to VOI/KYC procedures with version control and staff acknowledgements.
- Breach‑response runbook: roles, containment, evidence capture, and a decision tree for timely OAIC notification.
- Privacy governance: appointed a privacy officer; mapped retention and deletion workflows to business systems.
Now, when asked “show me,” they can—on demand.
7) Results: Contracts Refreshed, Dry‑Run Audit Passed
- Vendor contracts updated to cover AUSTRAC expectations and Privacy Act requirements, including incident cooperation and sub‑processor transparency.
- Formal reliance letters and assurance checks in place for third‑party KYC.
- Onboarding time down 20% with fewer reworks; escalations documented.
- Two suspicious activity flags correctly raised and recorded.
- Queensland seller disclosure workflow embedded ahead of 1 August 2025.
- Staff pass rate at 95% on the new SOP quiz; refresher set quarterly.
“We finally have a single source of truth—and we can show our homework.”
8) Outro: Your Next 10 Days
- Run a rapid compliance gap review (people, process, tech, vendors).
- Map data flows and declare systems of record.
- Update your privacy policy and collection notices using plain English.
- Refresh VOI/KYC procedures with risk‑based steps and evidence retention.
- Enforce SSO + MFA and least‑privilege access; fix de‑provisioning.
- Centralise logs; define audit evidence and an exception register.
- Refresh contracts with software providers for AUSTRAC/Privacy Act alignment.
- Train remote and in‑office staff using one SOP—the single source of truth.
- Run a dry‑run audit and remediate gaps.
- Schedule quarterly reviews so compliance becomes business‑as‑usual.
Start now; the deadlines won’t slow down. Document your business—or it will document you.