AML/CTF awareness for NSW agencies: what agents need to know for CPD

For the 2026–2027 NSW CPD year (1 July 2026 to 30 June 2027), anti-money laundering and counter-terrorism financing (AML/CTF) awareness for many property pathways sits inside one compulsory interactive topic: Supervision Guidelines and AML CTF in agency practice.

That is different from treating AML/CTF as a separate optional module, and it is also different from the separate Class 1 AUSTRAC requirement: AUSTRAC’s ‘Smart real estate agent’s guide to AML/CTF’. Class 1 holders in named areas of practice can complete that course now, self-paced online or through train-the-trainer. This article explains what agencies should understand from published Fair Trading guidance. It is not legal advice.

Why does AML/CTF sit inside a supervision CPD topic?

NSW Fair Trading sets compulsory topics by licence category and area of practice. For several pathways in 2026–2027, AML/CTF is not listed as a standalone CPD title. It is paired with Supervision Guidelines in a single compulsory topic name.

That pairing is practical. The supervision guidelines already expect principal licensees and Licensees in Charge to properly supervise people in the business, establish operational procedures for legal compliance, and monitor business conduct. AML/CTF awareness belongs in that supervision system (roles, procedures, training, and follow-up) rather than sitting in a binder that never reaches day-to-day agency practice.

In short: NSW supervision duties continue; AML/CTF does not replace them. The compulsory topic is about understanding how both layers work together in agency practice.

AUSTRAC obligations for real estate businesses started on 1 July 2026, with enrolment due by 29 July 2026. Those business obligations include an AML/CTF program, a compliance officer, staff training, customer due diligence, and suspicious matter reporting. That is what “agency practice” in the topic title now refers to. They sit beside, and are not replaced by, the CPD topic or the Class 1 AUSTRAC course. See AUSTRAC’s enrolment notice, real estate services guidance, and tranche 2 obligations summary. For what that staff training involves, see our guide to AML training for real estate staff.

Who needs the Supervision Guidelines and AML CTF topic?

Confirm your exact list on the NSW CPD requirements page. On the current published lists, Supervision Guidelines and AML CTF in agency practice appears for:

• Residential real estate salespeople
• Buyers agents
• Commercial real estate agents
• Business brokers
• Stock and station agents

It does not appear on the published compulsory lists for:

• Residential property managers
• Onsite (short-term) residential property managers
• Strata managing agents

Residential property manager compulsory topics are now published: 7 hours across 3 topics, and they do not include Supervision Guidelines and AML CTF.

If you hold multiple licence categories or work across several areas of practice, you must cover the compulsory topics for each relevant pathway. Shared topics generally do not need to be repeated if all required learning outcomes are met. See our 2026–2027 CPD requirements overview for the wider pathway picture.

How do the two AML-related requirements differ?

Agencies should keep these distinct:

Requirement	Who it applies to (published guidance)	Status
Compulsory topic: Supervision Guidelines and AML CTF in agency practice	Pathways listed above (and any dual-pathway combinations where that topic is required)	Core CPD for the 2026–2027 year from an approved provider, in an interactive format with assessment
AUSTRAC’s ‘Smart real estate agent’s guide to AML/CTF’	Class 1 licence holders in: residential real estate sales, buyers agency, commercial real estate, business broking, and stock and station agency	AUSTRAC's Smart real estate agent's guide to AML/CTF, self-paced or train-the-trainer

Class 1 holders also have a separate Fair Trading accredited forum of at least 5 hours, in addition to core CPD. Fair Trading will hold several forums in the 2026–27 CPD year, select approved providers can also deliver the 5 hours, and dual licence holders need only one forum. Our Class 1 vs Class 2 CPD comparison summarises those extras. For the Class 1 AUSTRAC course itself, see Class 1 AUSTRAC real estate AML training in NSW.

The AUSTRAC course may be self-paced because it is a separate Class 1 requirement, not approved-provider compulsory CPD. Self-paced study alone still does not count for compulsory interactive CPD. Those topics still need a live interactive webinar or a face-to-face session from an approved provider.

What should AML/CTF awareness look like in an agency?

Without inventing AUSTRAC rules that Fair Trading has not reproduced on the CPD page, a practical agency posture for 2026–2027 looks like this:

1. Know which people are on an AML-relevant CPD pathway

Map staff to licence category and area of practice. If their published compulsory list includes Supervision Guidelines and AML CTF in agency practice, that topic should appear on enrolments and on the agency training plan. Licensees-in-charge must have all CPD training detailed in the agency training plan.

2. Treat AML/CTF as part of supervision systems, not a one-off course badge

Completing the interactive topic is necessary for those who must do it. Awareness also means the learning returns to supervised practice: who owns compliance tasks, how procedures are kept current, and how the Licensee in Charge monitors that people are not left unsupervised. For day-to-day LIC habits around CPD and training plans, see our LIC supervision duties guide.

3. Book Class 1 holders into AUSTRAC’s course and file the evidence

For Class 1 holders in the named areas of practice, Fair Trading has confirmed the course and the two delivery pathways. Book them into AUSTRAC’s ‘Smart real estate agent’s guide to AML/CTF’ and keep the certificate or completion records.

4. Prefer current official sources over rumour

Exact customer due diligence timing, reporting clocks, monetary thresholds, and civil penalty figures can change with legislation, Rules, and AUSTRAC guidance. For public planning, rely on Fair Trading’s published CPD statements and AUSTRAC’s published course and enrolment pages.

How can EDUTIVE help with core CPD?

EDUTIVE is listed among organisations approved to deliver compulsory CPD learning topics for the 2026–2027 year on the NSW CPD page.

Browse the interactive compulsory topic Supervision Guidelines and AML CTF in agency practice (and your other pathway topics) on the CPD Course catalogue when you are ready to enrol. Always confirm your obligations against your licence arrangements and the latest Fair Trading guidance.

Frequently asked questions

Is AML/CTF a separate NSW CPD topic in 2026–2027?

No. Fair Trading lists it inside the compulsory topic named Supervision Guidelines and AML CTF in agency practice for the pathways that require that topic.

Which pathways include Supervision Guidelines and AML CTF in agency practice?

For 2026–2027 it appears on published lists for residential real estate salespeople, buyers agents, commercial real estate agents, business brokers, and stock and station agents. It is not on the published onsite short-term property manager, strata managing agent, or residential property manager lists. Residential property managers have a published 7-hour, 3-topic list that does not include this topic.

Is the compulsory CPD topic the same as Class 1 AUSTRAC real estate AML training?

No. The compulsory Supervision Guidelines and AML CTF topic is part of core CPD for named pathways. Separately, Class 1 holders in specified areas of practice must complete AUSTRAC's Smart real estate agent's guide to AML/CTF, either self-paced online or through train-the-trainer.

Does AML/CTF replace NSW supervision duties?

No. NSW supervision and licensing obligations continue. AML/CTF awareness belongs inside how agencies supervise people, procedures, and monitoring. It does not replace those duties.

Sources

Primary references used for this article:

• Continuing Professional Development requirements
• Supervision guidelines for property agencies
• AUSTRAC: Enrol now and meet your obligations
• AUSTRAC: Real estate services under the AML/CTF reforms
• AUSTRAC: Summary of AML/CTF obligations for tranche 2 entities
• AUSTRAC: Smart real estate agent’s guide to AML/CTF

Confirm your obligations against your licence arrangements and the latest Fair Trading guidance before relying on this summary.