Client: ClearTrace (cleartrace.com.au)
From 1 July 2026, Australia's Tranche 2 AML/CTF Act brought real estate professionals under the AUSTRAC compliance regime for the first time. Agencies face 19 distinct obligations across four phases — from enrolling with AUSTRAC and creating a formal AML program, through to ongoing client verification, suspicious matter reporting, and annual compliance reviews. The penalties for non-compliance are severe: daily fines of up to $19,800 per breach, criminal liability for officers, and a 3-business-day window to file a Suspicious Matter Report or face criminal charges. Yet no purpose-built software existed for the Australian real estate market. Agencies were left navigating complex legislation with generic templates, manual processes, and no clear roadmap.
We designed and built ClearTrace end-to-end — the only purpose-built AML/CTF compliance platform for Australian real estate. The platform covers every AUSTRAC obligation in a single product, guiding agencies from initial enrolment through to ongoing compliance with no legal background required.
We built a 19-item compliance roadmap tied directly to real AUSTRAC deadlines — the only one of its kind in the market. Across four phases, the platform auto-detects each obligation's status, surfaces consequence warnings for missed deadlines, and provides direct action links so agencies always know exactly what to do next.
Client identity verification is handled through a three-tier KYC workflow powered by Trulioo GlobalGateway — data match, document capture, and biometric liveness check. Full KYB is included for companies, trusts, and SMSFs. Agents send a branded verification link; clients complete the process on their phone; results come back instantly with sanctions screening included.
We built a RAG-powered AI assistant grounded in AUSTRAC guidance and each agency's own AML program. The Copilot is context-aware — it knows which page and client record the user is on, cites AUSTRAC sources in every answer, assists with SMR drafting, and flags compliance concerns in real time. Every session is logged for 7 years as compliance evidence.
The SMR module is architecturally invisible to agents — a tipping-off firewall built into the platform design. It includes a 3-day countdown clock, a formal continue/cease decision trail, and a simulated AUSTRAC submission workflow, ensuring agencies can meet the legal filing window without risk of inadvertently alerting clients.
Six role-specific AML/CTF training modules with scenario-based content, knowledge checks, and completion certificates. A training gate blocks agents from commencing client due diligence until required modules are completed — giving agencies an auditable record of staff training for AUSTRAC evidence.
The Transaction Tracker automatically calculates the buyer CDD deadline for every deal, with a kanban board, colour-coded countdown timers, and an auction mode that starts the CDD clock from hammer fall. For off-the-plan developers, a dedicated module handles bulk CSV import, nomination workflows, pre-settlement checklists, and project-level compliance reporting.
All data is hosted on AWS Sydney. The platform is SOC 2 Type II and ISO 27001 certified, with a 7-year immutable audit log and record retention vault built into the core architecture to meet AUSTRAC record-keeping requirements.
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