Proptech Panel: Proptechs Making AML Compliance Easy

https://www.youtube.com/watch?v=WMTBJVKUFvQ

New regulations meant real estate agents would soon be part of a national Anti-Money Laundering and Counter-Terrorism Financing (AML) regime. This legally obliged the industry to identify and report suspicious financial activities when working with vendors and buyers.

While full compliance does not start until 1 July 2026, agents and conveyancers were required to enrol with AUSTRAC from 31 March.

With requirements for new policies, processes, and compliance officers, it sounded - and felt - like a huge additional burden with terrifying consequences if it was handled incorrectly. But how much work was really involved? 

Australian proptechs worked hard to create software and solutions that integrated with existing platforms and workflows to take the guesswork out of being compliant with the new laws. We hosted a Proptech Panel on 25 February 2026, where our expert panellists shared first-hand how to be Tranche 2 ready without the stress.

What we covered

• Understanding the different verifications required.

• How to design a compliant process that fits within current workflows.

• What to look for in an AML provider.

• Tips for good decision-making to keep you compliant.

Transcript:

AJ Chand: Hello, it's AJ Chand here, CEO of Rezzo and part of the board here at the Proptech Association of Australia. And it's great to see you all here today for our discussion on making AML compliance easy.

AJ Chand: Before I begin, I'm here today on Dharawal land in Sydney and before I start, in the spirit of reconciliation, Proptech Australia acknowledges the traditional custodians of the country throughout Australia and their connections to the land, sea  and community. We pay our respects to their elders, past, present and emerging and extend that respect to all Aboriginal and Torres Strait Islander peoples joining us today.

AJ Chand: I'd especially like to thank the support of Stone & Chalk, who make all of these events possible. For those of you who don't know Stone & Chalk, it was founded as a not-for-profit in Sydney in 2015 to help fintech startups commercialise and grow. From 40 startups in 2015, it now has around 250 startups in Sydney, Melbourne and Adelaide, covering all areas of emerging technology, including proptech. Currently, around 20 proptechs call Stone & Chalk home.

AJ Chand: So, thank you very much to Stone & Chalk and the board of the Proptech Association for supporting this webinar.

AJ Chand: Now, this is a very important discussion today we're going to have around AML and I think there's a lot of curiosity around this topic. So, new regulation means that real estate agents will need to be part of the national AML (Anti-Money Laundering) and Counter-Terrorism Financing regime. That legally obliges the industry to identify and report suspicious financial activities while working with vendors and buyers.

AJ Chand: Whilst full compliance does not start until 1 July 2026, agents and conveyancers are required to enrol with AUSTRAC from March 31st. With its requirements for new policies, processes and compliance officers, it sounds and feels like a huge additional compliance burden and terrifying consequences if you get it wrong.

AJ Chand: But how much work is really going to be involved? To discuss this, I'd like to welcome our panelists for today: David Howell from Forms Live/Dynamic Methods, Alex Antal from InfoTrack and SecureExchange, Steve Grubmier from MRI and Ches Rafferty from easyAML.

AJ Chand: Gentlemen, thank you for joining me today. I believe this is a topic that's been on everyone's mind and looking at the audience today with the amount of people joining, it definitely is of interest, so I thank you all for being here.

AJ Chand: What we'll do is we'll jump straight in. The first thing, really, I think everyone wants to know is: well, what is AML, really? So, that's the first topic we're going to discuss. Before we move on, we just need to, obviously, address all the agents and everyone—real estate agents and also other proptechs that are on this call. And I think the first thing we want to discuss is: what is AML? So, Ches, we'll go with you from easyAML. Can you just give me a little bit of a description of what AML and counter-terrorism funding in Australian real estate actually means?

Ches Rafferty: Yeah, so obviously you've got the acronyms of what they mean. In reality, what it is, is it's an expansion of a system that's been in Australia for around 20 years and we've all experienced it in one way or the other—when you sign up for a bank account or an online gaming account, or even when you leave the country and you're asked if you're taking more than $10,000 out. That's all part of the AML/CTF system and what it's about is minimising the risk to Australians, or Australia more broadly, around the impacts of the crime from money laundering. At the end of the day, criminals create a lot of dirty money. They need to launder that money to make it clean so they can utilise it. And obviously, property in particular is a big area and a big vehicle for these criminals to launder their money through, which is why real estate professionals, along with a number of other gatekeeping services—such as lawyers, accountants, conveyancers and property lawyers—have also been pulled into this new Tranche 2 regime.

AJ Chand: Excellent. Thank you for that, Ches. So, when we talk about Tranche 2 reforms, can you just give me a little bit of a definition of what that means? Because there's a lot of names and acronyms getting thrown around here on AML and all this stuff.

Ches Rafferty: Yeah. If there's one thing that you'll get today from all of us, it is a pile of acronyms. It's loaded with new acronyms and things that you have to learn. So, yeah, we'll try to make sure we actually say what they are, because it can be a bit of an alphabet soup, as you sort of mentioned. So, Tranche 2—really, really simple. Tranche 1 was those businesses I spoke about. If you think about Tranche 1 businesses, they are the businesses that can directly facilitate money laundering. So, you know, you can wash dirty money through online gaming accounts or through casinos; you can launder it through bank accounts or through money remittance organisations. That was Tranche 1—where is that dirty money directly going into our financial system and being moved around to hide where it came from? That was Tranche 1 and that was done about 20 years ago.

Ches Rafferty: Tranche 2 was... well, at an international level, Tranche 2 was decided over a decade ago—almost 15 years ago now—that we would expand this to what was termed "gatekeeper services." So, they are businesses that we're not saying are wilfully involved, but directly or indirectly are helping facilitate money laundering. So, if you're a criminal, in the old days, you put it into a bank account, you move it around a few different bank accounts and that money is now clean. As they crack down on those Tranche 1 businesses, criminals start to say, "Well, how else can I move my money around?" And they do that through a variety of ways. Property: you could buy a property and then you could obviously sell it and then that money's come from a new legitimate person's loan account; you've got that sort of dirty money in cash and you've got electronic money out through the sale of that property. Very simple way you can do it. And there's other things, like lawyers and accountants, that can obviously help hide or obfuscate where that money comes from. So think about a complex trust or corporate structure. It can become very, very hard to understand who the actual people are behind that and that's why these other gatekeeping services have been brought in as part of this Tranche 2 change, which goes live, as you mentioned, on the 1st of July.

AJ Chand: Thank you. Alex, can we go to you now? Can you sort of talk us through, again, what is AML according to you and SecureExchange/InfoTrack? And also, where do the vulnerabilities exist within the property transactions?

Alex Antal: Yeah, perfect, thanks, AJ. So, I think there's a little bit to add, but I think Ches did a really good job in defining it. It really is about ensuring that we keep money clean and that transactions are indeed legitimate. So, in real estate, it's closely linked to identity fraud and transactional risk, which is sort of the genesis story of SecureExchange to a great deal, because criminals can use property to make deals using illicit funds to pretend they're somebody else, or to clean their money, as Ches mentioned earlier. So, the vulnerabilities that I think we've all identified—and obviously AUSTRAC and the government has as well—is that when it comes to onboarding new clients, when it comes to identifying the source of funds and how we actually handle payments. They're the sort of core vulnerabilities that I believe all products that are in this market are trying to solve for.

AJ Chand: Yeah, excellent. Thank you for that. I think, David—yeah, Dynamic Methods/Forms Live—can you show me, or tell me, how the AML connects with the agent workflow? So now, we talked about a lot of... obviously, we're trying to solve a lot of problems here, which I think is rightly so; I think we need to secure this industry and secure all Australians at that. So, also, just from an agent workflow perspective, was this messy, or how did this work?

David Howell: It's funny. Obviously, with the Tranche 2 stuff coming in, there's quite a lot to do to set up your business and that's something that, you know, the agents and principals need to focus on before July. However, the way we see it—and this is something we brought in last year with Ches through Scantech as well—was another alphabet soup, VOI: Verification of Identity. The way I see it is this is an extension of VOI, because you are verifying the identity of your purchaser or seller or customer, but then you're going an extra level and you're applying a risk assessment on top of that. But in essence, on a day-to-day basis, that's effectively what you're doing. You're assessing the risk of a particular transaction while verifying the identity and knowing your customer (KYC). So there's, yeah, lots of things going around in terms of how things will be difficult, or easy, or things like that. However, we see it as: if you're running best practice and you're running through platforms like Forms Live, we make it as easy as possible and kind of just streamline the process through your normal day-to-day routine.

AJ Chand: So, how is it done now? Like, you know, obviously, you think that the standard would be the KYC and checks around AML and maybe even PEP for that—which is Politically Exposed Persons for everyone on this call. So, what happens right now in that aspect? Are we still doing the KYC? Are we still doing the anti-money laundering checks?

David Howell: I think that the short answer is probably no. I think there would be a level of it going on, depending on the type of transaction that's out there. But I mean, the advantage of this Tranche 2 is it does kind of define very well what you have to do to comply, which has always been the concern from an agent's perspective: "What do I need to do to comply with these rules and make sure that I'm not putting any of my transactions at risk?" So, I think it's a good step from that perspective. If you're looking at the starter pack that was put out by AUSTRAC, you know, there's a lot more paperwork, which is obviously where we come in and can help out and that's where a lot of the providers like easyAML can provide too. But at the end of the day, it's just about knowing your customer and getting a better understanding of what's happening with your buyers and sellers and in most cases, it will be reasonably straightforward.

AJ Chand: Excellent. Thank you, David. Steve, to you: you obviously represent a lot of CRMs and other proptechs that are within your ecosystem as well. Can you just, you know, give us a little bit of what's happening behind the scenes over there at MRI and how you guys are discussing all this?

Steve Grubmier: Yeah, thanks, AJ. As you can probably understand, MRI is in a fortunate position to be able to utilise our scale and breadth and feedback from our customers across the marketplace. One of the things that we've learned—and it's consistent across all different verticals that we operate in—is that agents need seamless workflows to maintain that compliance. We're working furiously within our product folks, with our customers and with our suppliers to ensure that we're working in collaboration with one another. While some of the legislation is most recent, March 31st is the date for their registrations. We want to make sure that we're getting ahead of that. We released our first iteration of our AML workflow tool in Vault late last year. Box+Dice followed shortly after. We've since made changes to that because it is evolving over time and I think it will also evolve for agents as well. What they will learn from day one will be different from what they know on day 30, day 60 and day 90.

Steve Grubmier: So, I think what the agencies need is to ensure that their businesses—whether they're corporate, franchise, or boutique offices—get the support they need and have the answers at hand. We work with a number of different solutions providers, easyAML being Ches and the team. We've vetted out a number of providers, but it doesn't mean that they will be the only providers that we use in the future. This is the first cohort that we've brought on to ensure that we've got the best of the best in breed in market at the first day it goes live. So, I think for us, we run a very strict due diligence process around our partnership programme. We have a governance, compliance and risk assessment that's run globally, so we uphold our partners, but also ourselves, to the highest standards and that standard will grow over time. So, agencies should feel assured that we have their best interests at heart and also that workflow will be an ongoing development programme for us. If I think about, "Are we ready for the marketplace?" To be honest, we are confident with our position and our workflow status. I think there will be changes that we will need to make, as every other business will. We're working closely with our partners to ensure that we've got that seamless workflow to reduce friction, to improve productivity and maintain that level of compliance, which is really something that we're proud of.

AJ Chand: The good old tech philosophy: build, measure, learn, right? Because this is what this will need to be. And where are you guys getting all these regulations and data? How do you even know what to look out for and what do you do? Is it... are you collecting that directly from AUSTRAC and analysing what they're doing there?

Steve Grubmier: Yeah, we've got several partnerships. For us, we're the core system of record, so we're not typically building out a solution for AML; that's where we bring in our partners. They go through all that legislation, the workflows and documentation. Some of that information we do have on hand, so they will call our APIs for different purposes and push back the right information. We're trying to make it streamlined for our customers. But I think we lean on our partners to be able to deliver that solution and we'll surface what we can. I think we're in an awesome position to be able to set the expectations for the industry and take it to the next level. One of the things that I do want to talk about is more about being customer-focused and delivering those outcomes for the customers, so we might make a couple of mistakes. That's okay. We live, we learn, we build, we iterate. If anybody says that they're perfect, then I would question that.

AJ Chand: For sure, I think this is an ever-evolving thing, right? This problem has been in this market for as long as this market has existed, I would assume. Thanks for that, Steve. Ches, back to you. And I know we touched on this before around identity fraud and all of that, but why now? We could have done this a long time ago. And what has AUSTRAC made available as well?

Ches Rafferty: Yeah, look, the simple answer is, as I mentioned, Australia is a founding member of a body called FATF, which is part of the OECD. Basically, it's called the Financial Action Task Force and it regulates what the global rule set is for how we're going to minimise money laundering and criminal misuse of financial systems. Unfortunately, whilst Australia was a foundational signatory, we have dragged our feet for 15 years to implement this. To give you some context, New Zealand did this 6 or 7 years ago; the UK implemented this about a decade ago. So, we're very, very far behind and we're literally one of a handful of modernised countries that has not implemented it.

Ches Rafferty: We have a review in November this year. So, effectively, if we did not pass these rules and get them implemented, we would get on what's known as a "grey list," and that is not a good global list to be on. It would cause all kinds of wide systemic damage to the Australian financial system, like increased borrowing costs, etc. So, Parliament passed the Act in November 2024 because of this deadline in November '26. A two-year window is a very small timeframe to run this through. So AUSTRAC—who is only acting in their role from the regulations passed by Parliament—has had to really rush this through at a very rapid pace. And they've done, I think, a really good job considering the limitations they've had. The Act's been passed, there's been regulations that have had to pass Parliament, there's had to be guidance and then there's had to be sector-specific guidance.

Ches Rafferty: Tied in with all of that, AUSTRAC made a decision to create what's known as "starter kits," which are sort of an end-to-end document set including forms of what you need to complete to be compliant for these new Tranche 2 changes coming in. So that's everything from your obligations around a risk assessment for your business, a programme policy document for how you're going to manage and minimise your risks, high-level advice on what to look out for, how to onboard customers and—as Dave said earlier—how to undertake risk assessments for each transaction and each client and how to report to AUSTRAC. So they've done all this, but what it has meant because of this huge amount of work and the very short timeframe is—to Steve's point earlier—for the providers like ourselves and InfoTrack, we've got a very short window to take all that advice and to understand what systems we need to build to make sure our clients end up being compliant.

Ches Rafferty: It's certainly been a very, very rapid process. To give you an idea of the scale, these starter kits I'm talking about are sort of 300 pages in length with sort of 20-odd forms that you may have to use—for everything from whether you're onboarding an individual, a sole trader, a business, a partnership, a company, or a trust. And there are ongoing reporting obligations that you have to do quarterly or annually, depending. So, we've had quite a compressed timeline. A lot of work has been waiting for this information to come out so that we can finish building it. Again, as Steve said, I don't think anyone's going to proclaim they're going to be perfect. Even currently, AUSTRAC is talking about changing some of the guides or rules they've already put out for the broader benefit of implementation, so it's actually positive, but it does mean there's going to be a bit of a run to the finish. It's not really possible to have been ready 6 or 12 months ago because we just didn't know what we needed to comply with in detail.

Ches Rafferty: So, yeah, it's been complicated and I guess that sort of answers the "why now." In a perfect world, we would have passed this legislation five years ago with a 3-year window to implement. That's not what's happened and that's sort of where we are. We're all dealing with it. And look, to be fair, in the other direction, AUSTRAC has been very clear: as long as you are actively and genuinely participating in this process, they're not going to come out and penalise people for innocent mistakes or small technical errors or hiccups. If you choose not to comply deliberately, then that's a very different story. But I think most businesses are very much focused on what they need to do to comply.

AJ Chand: So, as a real estate agent—excellent. I am a licensed real estate agent; I have sold property in the past before getting into property technology. If I was to navigate this by myself as a licensee of a real estate agency, you're saying that I'd have to go and read 300 pages of a document, kind of understand it, then implement all those forms into my business, fill in all those forms, then I'm guessing I'm storing these forms somewhere, including identity? Would that be correct as well?

Ches Rafferty: You have to keep the record that you've identified them, yes and you have to securely store that for 7 years. So, a minimum of 7 years. Look, we're all on a proptech event; we're all technologists on this call. The simple answer, in my opinion, is I don't think our clients have the time to implement these forms. Yes, obviously, it's free versus having to pay a technology provider, but free in one sense—what is the actual internal HR cost going to be for you to manage this? Let alone talking about the systemic risk, because if you're manually managing these forms—and you've got dozens of forms that you have to fill in—you have to know when to fill them in, how to fill them in, you have to store them and you have to report on these forms. So, you've got reports about reports. I personally don't think many businesses could afford to do that, because you might be talking about a full-time equivalent employee or a .5 FTE. Can you really justify that when you can go implement a technology partner for a fraction of that cost? It's totally up to you, but we're all in technology because we believe that technology is one of the most powerful levers that you can utilise to improve your business, particularly if you're a smaller business.

AJ Chand: Excellent, thank you, Ches. To you, Steve, now: what are the discussions being had at the board level right now around this governance and this change? Obviously all the CRMs that are part of MRI and pretty much all the technology... this is a pretty big regulatory change. As someone who's into software development, it just seems like there's going to be a lot of experimentation going on within these platforms to make this available. What are you seeing there, Steve?

Steve Grubmier: AJ, I think for us, we're quite fortunate. David Bowie, who sits on the board with you for the Proptech Association, he's been through this in a commercial environment—so he's worked at different organisations. One of the things that we benefit from is we operate globally, so we're in the UK marketplace, New Zealand and the US. We've looked at some of the reforms out of the UK. In fact, Vault was operational pre-acquisition of the PropTech Group and we did have an AML structure for the UK marketplace. So, we took some of those key learnings and brought them back to Australia. Now, at a board level, there is a lot of visibility on where this is going, what we're doing and how we're supporting our customers, because at the end of the day, we need to make sure that our customers are adhering to their regulations around Tranche 2.

Steve Grubmier: We are satisfied with some of the solutions that we've got. Again, I'll come back to: it will continue to evolve over time. We will go deeper. At the surface level—if I refer back to Ches—up until 5 months ago, we didn't know what the final rulings were. So I would only expect AUSTRAC to firm up their position and also improve the position to make it easier for agents to remain compliant. But it is a priority for us to make sure that we're giving our customers exactly what they need, when they need it and with the least amount of friction possible. If I think about some of the other providers out there, they will be able to operate outside of MRI for the time being. It'll just require a little bit more manual workflow. But they won't be restricted to just working with the partners that we've integrated with. They'll come through as another cohort, so we'll bring them in at some point as well. So more choice, flexibility and freedom to choose the solution that fits their need. We know that every customer's different and I think we will have a solution for a majority—I would say 99.5%—of all of our customers. Those 0.5% will come back to Ches' manual process; you know, they might only list one property or two properties a year, or one or two a month. So, it might not be worthwhile, but again, that comes down to their reputational risk and their processes—if they've got the capabilities in their own business to be able to deliver that and maintain that standard as well.

AJ Chand: Thank you, Steve. Alex, to you now: how long has this implementation taken for SecureExchange, for example? I'm just trying to get the depth of how long has this been worked on in the background and now it's coming to form.

Alex Antal: That's a great question. I think we're really fortunate in SecureExchange and InfoTrack more broadly that governance and governance change is sort of our bread and butter. So, we deal with these sorts of things—maybe not to this scale; hopefully none of us have to do it to this scale too frequently—but if I refer to those Queenslanders on the call, SecureExchange sort of led the way when it came to dealing with the seller disclosure regime that hit us in August of last year. Through that, we got to validate and understand the behaviour and needs of real estate agents when it comes to governance change.

Alex Antal: I sort of slightly disagree with some of the statements of the panelists earlier in respect to readiness. I think that we're, again, quite fortunate in the sense that annually, through our business, we do about 5 million checks that are related to what AML exactly is going to be already. So, I think we've got the pedigree and understanding to be able to facilitate this really well. And on top of that, when it came to being ready, what we also chose to do was not to rely necessarily on the frameworks of foreign jurisdictions, but rather build something that was proprietary to Australia. Obviously, like we all have mentioned AUSTRAC, but we also gained the guidance of Grant Thornton as well. I'm sure many of you know Grant Thornton, but they've helped guide us to make sure we're building a product and a solution that is compliant, but also market-fit. So, maybe a long way of answering your question, but for us, this has been not just the last 6 months or the last 12, but something that, as a business, we've been built to do for the last 15 years. This is an extension of that. So, I don't want to say we're perfect, because Steve will come after me, but we feel like we're as ready as we could be. We're hitting the ground from the start of next week with a series of events across Australia to start to share in more detail so everyone can feel really comfortable as to how we are going to service them. Most importantly—and I'm sure we'll get to it later—as to how we specifically service real estate agents and have them be able to rely and work with their network (be it lawyers and conveyancers) so they don't have to do this governance heavy lifting that they might be afraid of right now. I think there are ways and means to make this a lot simpler for the real estate agent and the real estate businesses and proptechs as well, to really service the industry. So, yeah, a little bit of a long-winded response to your question, but yeah, we feel really quite ready.

AJ Chand: I think the more I look at this, there is no short answer around this at the moment and I think that's what's causing a whole bunch of confusion. Thank you for that, Alex. David? To you now: you represent pretty much all of the people in a transaction, right? So you've got the agents, the buyers, the sellers, maybe even property managers, tenants and conveyancers. So there's a whole bunch of that cohort on this call as well. A lot of them have different titles and different roles. Is it a one-size-fits-all? Does everyone need to do this blanket across real estate, or are there specific guidelines, you think?

David Howell: So, first of all, just to answer some questions that came in: the 300-page document we're talking about is... AUSTRAC—and I think Ches did put in the chat the link to the AUSTRAC website—that gives you the kind of bundle pack. It's called a "starter pack," and there's a bunch of documents—some documents describing the things you need to do as a principal to set up your business, others on what you have to do from a day-to-day perspective and then others in terms of what you have to do on a year-to-year basis, or every three years. But the focus here is on the transaction of a property, as in a sale of a property, not in property management at this stage. I suspect, though, that some of these things will start to filter through these different scenarios. So, I think it's important that if you're in real estate, you do get an understanding of what you need to do for this. One question, Kylie, you had in there around... let me just bring it up... "Will it be the job of the real estate to catch money launderers and financial criminals through these changes?" My answer is: I don't know, but it's about reporting it. So, it's about understanding and giving the government the ability to track down these people faster with more information and I think the real estate industry can help with that. There are certain rules you've got to abide by in terms of tip-offs and things like that, too. No, this is about reporting, it's not about catching and I think Ches would probably agree with that. But yeah, in most cases, this shouldn't affect your sale or transaction of a property. It's just a little bit of extra paperwork; depending on the type of entity that you're dealing with, it can get a little bit complicated.

David Howell: But, a little bit to what Steve and Alex were saying before as well, Forms Live... we kind of cater for everyone. So, those agencies who are doing one property every few months—things like that—we do support that type of customer who wants to do it themselves or can't see the financial benefit of signing up with a big platform. They can do the KYC onboarding and the customer due diligence all through Forms Live. They can track all those, get the identification manually through their own means and then store it within Forms Live, or go all the way through to a full integration with, say, easyAML, where while you're setting up your agency agreement, you click a button and it says "initiate the KYC/AML process," and that starts in parallel. It's all completely hands-off and in most cases will be completely digital. So, we'll be supporting all those scenarios and everything in between. And yes, it will change over time as things go out, but for us, it's an extension of what we've been doing all along, which is around forms, compliance, legislation and bringing proptech in to make that easier.

AJ Chand: With Forms Live, does the customer have a choice as to the AML provider they use within Forms Live, I guess?

David Howell: Yes, absolutely. I believe at launch, we will have more providers available than anyone else. We really want to give people choice. Obviously, I'd love to give a demo today of just how easy it is to connect to easyAML at the moment. It's really... from that point of view, that's what our job is as proptech—to try and make this as seamless as possible. This is not about putting fear into the industry. It's all about: how can we solve these problems easily and seamlessly and work together? The great thing, I think, about the people in this webinar—from SecureExchange, MRI, easyAML and us at Forms Live—is that while we do overlap in a lot of things, we kind of all work together as well. So, MRI integrates with Forms Live, Forms Live integrates with easyAML and Forms Live into SecureExchange. We're all kind of talking together and the idea is that we solve this problem together as well and that our mutual customers don't have to do things multiple times or in an inefficient way.

AJ Chand: Thank you, David. Now, we've touched on this before, but what is the actual problem we're trying to solve here? Is it... when we talked before about the implications to our financial services... but is it really a problem of fraud in this industry and that's what we're trying to solve? Or is it more what we've committed to from a financial sense? Alex, we'll go to you on this one. I'm trying to get my head around the events that took place in terms of identity fraud and maybe even some more publicised ones as to why we are in this space now and trying to solve this problem. So, if you can take us through and kind of point out what SecureExchange has seen over the years that were really big risk factors to the property industry or transactions.

Alex Antal: Yeah. So, a quick little story about how SecureExchange came to exist. The founder of InfoTrack was trying to secure a property transaction while he was in the UK, I believe. And he was, in an instance, sent two emails by the real estate agent as to where to transfer monies into trust—one being legitimate, one being fraudulent. From that point on, we endeavoured to ensure that parts of a property transaction that are controllable when it comes to managing fraud, we are certainly front and centre in doing that. That was the case when SecureExchange started 7 years ago and continues to be the case as it extends into AML. So, when it comes to the protection of identity, the knowledge of where funds are coming from, as well as identifying anybody that might be politically exposed, they're all the other problems that—be it SecureExchange or easyAML or any other vendor—we're all trying to solve the same problem.

Alex Antal: I think where, more specifically for SecureExchange, the problem that we're also trying to solve is that of not asking the agent or the consumer to have to do things twice. So, how we're attempting to solve that is through the concept that is allowed for within this regime and it's called "reliance." If you haven't heard about it, I'll give you the cliff notes: essentially, through reliance, one party is allowed to rely upon another for the completion of the AML checks. InfoTrack and SecureExchange have about 90% of lawyers and conveyancers using us already. So, in that instance, an agent, with the facilitation of a reliance agreement, can simply rely upon the AML checks that have been performed by the lawyer, which we know 90% of the time is likely to come through InfoTrack. What that means is the agent doesn't have to go through a lot of the arduous transactional work. And also, what it does mean is that the consumer doesn't have to do things multiple times, because there will be instances where the consumer will be asked to do AML checks from their lawyer, from their conveyancer, from their agent and from any other source. We are really endeavouring to solve that problem of avoided data duplication and the replication of work for our agents, but also for the consumers—the clients of our clients.

AJ Chand: Thank you, thank you, Alex. Ches, to you: how do you deal with complex ownership structures? Obviously, everything's not just bought by mum and dad investors, or in their personal names. There are trusts, which are very prominent and international buyers as well. How do you even go about tackling that? Do you need to verify everyone? Everyone needs to go through checks, directors included?

Ches Rafferty: Yeah, it's a great question, AJ. Look, at a high level, what AUSTRAC is trying to do is to understand who are the people behind a transaction. Obviously, as you just mentioned there, there's lots of complex structures that are completely legitimate, whether that's complex corporate structures in businesses or trust structures. The problem is, they're the same sort of methods that criminals also try to use to obscure their ownership. So, you've basically got to have "who benefits" and "who controls" these structures. Let's take companies, which are a bit simpler to understand. Obviously, directors and secretaries of a company are controlling that business, so you have to identify them. That's very clear. And then, if there are people that have a direct or indirect ownership of 25% or more of a business—they're known as Ultimate Beneficial Owners (UBO)—you're required to also verify them. When I say "direct or indirect," if you think about a situation where Company A is owned by companies B and C, you need to understand who owns B and C. Perhaps I have some shareholding in Company B and some shareholding in Company C and when you add up those averaged amounts and I control 25% or more, then you'll need to also verify me. Obviously, if I'm also a director, you only have to do the verification once. Trusts, again, are a bit more nuanced, but if you're talking about your general discretionary trust, you need to identify things like the trustee and the named beneficiaries of that trust as well. So, it certainly can be more nuanced than what we've seen in historical property transactions, where generally, if it's a company, it's a director and maybe it's a trustee if it's a trust. These are some areas that are a little bit more complicated. Again, using the right technology providers will do most of that heavy lifting for you and identify the individuals that we need you to identify and then you do those KYC checks on those individuals.

AJ Chand: Excellent, thank you. So, what about international buyers, then? If you've got international buyers transacting or maybe even an international trust, I'm guessing that these trusts and buyers will be harder to verify, simply because they're sitting overseas and they're not following the same guidelines as Australia. So, do you think this will deter agents from considering international buyers for sales, because it's easier to get an Australian buyer?

Ches Rafferty: A sale's a sale, right? Look, I definitely think if you've got two buyers that are exactly the same and one's very simple and one's complex, the likelihood is you might tend to target the simple one. I also think there might be some good opportunities for some businesses to become more specialised in these areas—not just real estate, but transfer businesses in general. We look after more complex clients; perhaps they get higher value from looking after them. So, I definitely think there are likely to be some businesses that see opportunities from this and really go after it. But at the end of the day, if you've got a buyer and there's a little bit more work to be done because they're international, using the right provider should be able to simplify that task as well. It's very clear with AUSTRAC: they don't care whether or not you're domestic or international. From their perspective, it's just about understanding those risks. Obviously, an international complex structure with PEPs is much more high-risk than a local individual buying a property with a significant home loan that a bank's also done a lot of verification work on. So, it's really about understanding those risks and then making sure you have the right processes in place to meet your AUSTRAC obligations.

AJ Chand: Excellent. So, just on that as well, discussing the easyAML solution: can you take me through a little bit of what logic you guys used, or what you thought about when you were developing all of this, or any red flags or anything that you wanted to avoid while building?

Ches Rafferty: Yeah, look, I think Alex mentioned it before and I agree with him at a high level—there are very key parts of these processes. easyAML's been spun out of our parent company, Scantech. We've been doing identity verification for coming up on 15 years. When we first looked at this process, the customer due diligence—the KYC and the KYB (Know Your Business)—was really what we started to look at. It's pretty much what we did. It seemed a very simple part for us to tackle and it is the part that these businesses, the real estate agents, are going to deal with mostly day-to-day. When we started digging into it, the red flag that immediately came to us—even before all the guidance had been released, because there were acts and information out—was that the level of compliance for Tranche 2 businesses is exactly the same level of compliance as a Tranche 1 business. The difference being we're talking about banks and large organisations, generally and now we're talking about small and medium businesses.

Ches Rafferty: You can't just go hire a team of 5 people to manage this. If you're a 10-person company, you'd go out of business. So, the red flag for us really became: how do we provide an end-to-end tool that does everything from your risk assessments, creating your programmes and policy and procedure documents and training your staff? Doing your customer due diligence on an ongoing basis, reporting to AUSTRAC and keeping all that information stored and secure for 7 years so that you're meeting all your obligations. How could we build a solution that became relatively cheap—because there's always a cost—but relatively cheap, particularly when you consider the overhead cost to you if you're going to try and manually implement it? That was really the red flag at the highest level we were trying to solve. We really think we've achieved it. Obviously, another part of that was making sure we work with great partners like MRI and Forms Live, because we don't want to be that record of source. We want to be really doing AML well; we don't want to just send forms out. We really want to just do the bit that people need to be done right for AML and let our fantastic partners do what they do really well and handle that sort of day-to-day interaction that our clients are already used to doing.

AJ Chand: Thank you, Ches. David, to you now: can we just have a little chat about the workflow integrations that you went through and the logic that you used to go through that? How do you reduce the friction and duplication of all of this data and make it seamless for the agent?

David Howell: Well, I mean, probably the best way is just to do a little demo. If you don't mind, I can share my screen quickly. I'll kind of cover off on the two scenarios where this might be someone who wants to do it themselves—perhaps they want to do the onboarding, the KYC and the VOI themselves. They can actually do that through Forms Live through the AML forms that we will be putting out there. Now, these are based off the AUSTRAC starter packs, where you can start to gather information for your customer.

David Howell: So, here's one I prepared earlier: this is the onboarding for an individual or a sole trader. Perhaps you don't have all the details because you might not be in front of them filling out this form yourself. You could actually send this off via an "Info Request" and get the customer to fill it out for you. So they can fill out all these details and this is the beginning of the onboarding—finding more information about your customer. Obviously, part of that process is identity verification, or you must provide certain primary identification documents like passports and driver's licences. So then you can upload those files and save and complete into Forms Live. It's very, very simple, but doesn't have all the bells and whistles, say, an easyAML process would. Obviously, what we will do is these forms will be related to your normal day-to-day forms, so if you've got an agency agreement, this could go straight into this onboarding form for your vendor.

David Howell: Or, you can connect to a system like easyAML. If I go over here to "Connections" and then I connect to easyAML... this connects very quickly because I've done it previously. Normally, what I would typically do—let's say I'm trying to sign up a vendor to sell a property and here's one I've got prepared earlier and the vendor is myself—I can go straight over here to my AML/KYC sidebar and that loads straight into easyAML. I can just click "Submit Request," and that effectively starts the process that I just did before with the onboarding, but all through easyAML. So I can go in here and in "Entities," I can list individuals—and you can see here David's popped up. In the meantime, I've got my SMS here on my phone as a customer and I start my ID verification process and start answering all those questions.

AJ Chand: This will be a similar process for SecureExchange or any other AML provider you've got within Forms Live?

David Howell: Correct. I mean, SecureExchange, I think, will be very interesting as well in terms of how that integrates. Like you were saying before, Alex, you answered one of those questions in the chat about reliance—about sharing information between businesses. But also, if you're only doing a few transactions, what can you do? You want to be able to leverage the technology but not have to pay a big amount and I'm sure there'll be solutions for everyone in all those different scenarios.

AJ Chand: Thank you, David. Steve, to you now: obviously, MRI's got a lot of CRMs. How do the audit trails, the governance and the CRM integrations work? Have you had a chat with the CRMs in your cohort and how they're going to centralise all this compliance data? Are they going to hold it within the CRM, for example?

Steve Grubmier: To answer that question, no, we won't be. A lot of that information will be stored with the partners. We're working closely with the partners just to make sure that we've got the right information at the right time for the right reason. So that might mean one product or another. Typically, a vendor will only go through one CRM or an agency at Vault, so we won't have to share that information amongst the CRMs. At some stage, we might have various buyers of a property that's sitting within Box+Dice or Eagle, for that matter. At some point, we might be able to have that reliance piece sorted to assist or reduce the cost to the customer and then improve the productivity for our client.

Steve Grubmier: But the one thing that I think about is the risk—we're trying to be risk-averse. Our partners do an amazing job of storing information. They've done their due diligence and they're upholding the highest standards in governance, compliance and risk assessments. We're happy with them holding onto all of that information. Yes, we still hold a lot of information, but we have our own protocols that sit behind that to ensure that it's safe and secure. The information that we exchange is on a subscription-based service; so if a customer has to subscribe and connect into an easyAML of sorts, they have to do that and licence that software. I think for us, reputationally, we've got a reputation to uphold—first-class standards. For our customers, they have a risk as well, so we're trying to be risk-averse for them as well—enabling them, thinking about the corporate entities, the boutiques and even the individual operators across the network. We want to make sure that we can help them remove that risk, become compliant and really take the fear out of the process. We've seen New Zealand go through it—they managed to get through AML. We've seen the UK marketplace. The world didn't stop, alright? So, I think we will continue to roll. Yes, there will be changes, but I think we can take ease in knowing as long as agents do the right thing and follow the rules. Like Ches mentioned earlier, if they miss one property or if they don't run that check... in the MRI world, we've put certain gates here to stop the property from going live, for example, before they've run a name check. On the buyer side, it's a little bit different—is it an auction, or a private treaty, etc.? So, they're different scenarios. We're trying to take into consideration the mass market, which is 90-plus percent of all transactions and taking that sort of approach for scale. That's what gives us the confidence. New Zealand comes to mind a lot. I think our approach and the AUSTRAC approach is similar to a mixture of the NZ and UK, but it is different to both as well, so there's some uniqueness to that.

AJ Chand: Excellent. Thank you, Steve. Alex, to you now: take us a little bit behind the scenes of how identity verification works and how you guys protect the final stage of the transaction and also the document exchange. I guess, for all the real estate agents on here, how does that process work, especially in identity verification?

Alex Antal: Yeah, I think just before I get to that, one of the points that I think Ches and I and everybody would agree on—and Steve mentioned it—the right partner for an agent or a proptech is not a partner that is going to take personally identifying information and send it outside our system. That is the biggest of the no-nos. I would... if you were assessing vendors and if that wasn't part of your criteria, perhaps it should be. But I'd assume everybody worth their weight in salt would say they could do that. For us, as I said earlier, InfoTrack does about 5 million verifications of identity and other associated documents annually. A lot of that is done through lawyers and conveyancers. So, we're going to mimic that process and add it to the other elements that are attached to AML—be it the politically exposed persons and the source of funds. So, we'll continue to do it in the way that we have, in the sense that the agent or the lawyer will ask a consumer to identify themselves. That can be done through a liveness check, or through the standard way of licences and 100-point ID—all that stuff that's been around for forever and a day. That will be securely stored within our systems and then results shared appropriately. If it's the lawyer doing it first and then the agent wanting to get access to that, we'll essentially say to the agent within SecureExchange: "Hey, you can now access that report." My product team will hate me saying this, but there'll be some sort of flashing light to say it's now ready to be consumed from your end without you having to do any of the heavy lifting, Mr. or Mrs. Agent. From there, we'll continue to protect the other stages of the transaction, which is the transfer of monies and all the way through to settlement. So, SecureExchange fundamentally won't change, apart from this additional layer of ensuring that our clients are compliant when it comes to AML and have access to the AML searches that their referral network has already done.

AJ Chand: Excellent. Thank you, Alex. And I agree with you there—identity fraud actually comes from mishandling identity and then recirculating into identity fraud. This has been a huge problem in real estate for a very long time, especially in property management and in sales. You're photocopying copies of identity, licences, Medicare and 100-point checks and then you're storing them in a file. That's historically how it used to be—storing in Google Drive or trying to secure them is also the same problem. So, this seems like as long as they stay within this AML ecosystem, it's all compliant; they can run the checks and not run the risk of losing this. Okay, just on final, before we answer some questions here: I'd like to get some advice from you guys for real estate agents that are on this call today. David, I'll start with you. Can you just give us some advice for all real estate agents that are listening to this call, or maybe even some proptechs that service real estate agents?

David Howell: Some advice. Well, everyone on this webinar will be sending out information to our customers around how to prepare and be ready. Especially the likes of SecureExchange and easyAML. I think, as a principal, there are two parts you need to kind of really understand. There's the preparation part—preparing your business for this change—and then there's your staff and what they want to do on a day-to-day basis. So, you've got plenty of time at the moment to kind of get your head around it as a principal—to understand what your obligations will be as a business owner to set up some basic policies and things like that. Again, this is where tools within easyAML really make it easy to get an understanding of what your policies and procedures might be. And then, really the best thing is to look into it—have a read. Maybe not all 300 pages, though you can—I've read them a few times. But really... yeah, try not to stress about it from the perspective that—as Ches was saying—really, this is about knowing your customer better and assessing the risk on a particular transaction. That's really what it comes down to; you want to have a better picture of your customer. And in the chat, I can see people are talking about ID verification already happening in the conveyancing stage. So, a lot of this stuff is already happening in the transaction; it's just being brought forward. A lot of it isn't new. And similar to what Steve said: New Zealand has been doing it, the UK has been doing it and things haven't stopped. Life goes on and transactions will still occur. So, I think the best advice is really to stay calm and watch this space in terms of the information that's going to come out from all of us: Forms Live, SecureExchange, MRI and easyAML.

AJ Chand: Cool. So, what I take from that is you're just identifying the risks earlier, instead of getting to the end of the transaction where you're trying to identify the risk there and hopefully everyone will catch these before it gets there. Ches, do you second that? Do you think that's where it's headed?

Ches Rafferty: Yeah, look, absolutely. And look, I think, tied in with "Keep Calm," I think the big piece is that there's multiple parts to this. Putting technology out of sight for just a moment, there are change management processes that you need to do as part of this—things like your collateral and communications with your end customers. I think that's really important. I think a big part of it—and why easyAML is working so closely with partners like MRI's CRMs and forms libraries—is because what we want to do for real estate agents and the other industries involved is to minimise the new learnings that they have to do. Having a partner that's integrated from an AML perspective into your existing workflows and your existing processes helps make this transition simpler, in my opinion. So, that's something I would look for—find out who they're partnering with and find providers that have good partnership relationships so you don't have to learn everything from the ground up.

Ches Rafferty: On top of that, start early. Don't leave this until May. Start doing your research now. I'm not saying you have to pick a solution now. Have a read, or at least have a look on the AUSTRAC website to understand the reforms and the guidance. Make a decision if you want to be—as Steve said, I think it'll be a small percentage—but if you're not doing a lot of transactions and you do want to use the starter kits, that's totally fine. But start now; don't get to the end of May and go, "I probably should look at this now," because that's probably going to cause you a world of pain. Small plug for easyAML: you can go on our website right now; we've got a free tier. You can sign up, you can do your risk assessment, you can get a programme, you can even start some of our training modules and train your staff. There are ways that the right providers out there can let you start quite literally today. Just go to easyAML.com, get started for free and have a play. Try your partners out, have a jump on their system, find out what they're like and pick the one that's best suited for your business.

AJ Chand: Awesome. Alex, we'll go to you. Same thing: advice for agents, or anyone on this call.

Alex Antal: Yeah, I think the advice that Ches and David shared there was really sound. It is not about panicking right now. For the folks that are on the call, you're doing the absolute right thing; you're trying to gain education on something that is being built up to perhaps be scarier and more detrimental than it will be. But interviewing the various vendors, seeing what their unique value proposition is and if that relates to your business needs, then that's the right choice for you. Continuing the education, understanding... and I'm going to take Ches' lead about a shameless plug... I'll drop it into the chat: we're running events across 24 different cities starting next Tuesday. That's free. Come along and learn more from Grant Thornton, AUSTRAC, InfoTrack and our partners as well. And secondly, it's about making a choice that has consumers in mind. I think too often, when it comes to real estate technology, we make the choice that is convenient for us and we end up with a really steep software stack that isn't to the advantage of the people that we ultimately serve. So, I would really think about the consumer experience, because I believe an agency can use the way they do AML as a competitive advantage and a unique value proposition that, when you're in the lounge room, is going to make a difference.

AJ Chand: Excellent. And to you now, Steve: same advice for everyone on this call.

Steve Grubmier: Good point, Alex. To follow on from that final comment there: I do think that this is an opportunity. It's also a challenge, a risk and a threat for some of our customers. But the best agents will use this as an opportunity to grow their business. They will take it on board. The one thing that everybody has here is we've all got the same rules to abide by, right? So, it's consistent across the industry, regardless of who you are or how big your organisation is. Larger organisations might have more governance that they have to apply, whereas I think a smaller business might be a bit more nimble. Use those experiences and use your business to your advantage. One of the things is: doing nothing is not doing something. Everybody's spoken about it—engage with the suppliers that you have. Engage with our sales team; MRI's got a dedicated sales team. Engage with them and find out who the suppliers are that they can reach out to and connect with.

Steve Grubmier: There is an opportunity, I think, for us to bring the industry forward. Yes, we are, in some verticals, competitors—there's crossover on this panel. But we're all working on the same goal and that's to create productivity, performance and also reduce liability for our customers. I think we're aligned there. Choice, flexibility and freedom of solutions... we have 3 CRMs, so choose your provider accordingly to your business. Finally, I'll just say: if I was an agent, I wouldn't leave it until the 31st of March to register. If I was a business, start planning now and make sure that you're well ahead of the incoming changes.

AJ Chand: Excellent. Well, thank you all. That's all we have time for today. I really appreciate you taking the time. This is a very important topic and there's a lot of confusion around this, which I think you guys have made a lot simpler, especially with the tech that you're building. So, I appreciate that. And also to let everyone know on the call that easyAML and MRI are running another webinar on this as well. Alex and David, you'll be doing webinars for all of your clients separately to this. However, the Proptech Association really wants to help with this change and especially help our upcoming proptechs understand this. So, I do appreciate your time. Thank you very much, thank you to our sponsors and thank you to the Proptech Association Board. Have a great day.

AJ Chand: Cheers, thank you very much.

Steve Grubmier: Thanks, of course.

Alex Antal: Thank you.