For Australian real estate agencies
Received an AUSTRAC section 167 notice?
AUSTRAC is issuing section 167 notices to real estate agencies it believes provide designated services but have not enrolled. We review your agency, map the notice and index your records within seven business days, so you can respond accurately and on time.
Fixed fee, confirmed before work starts · Seven business days from a complete intake · You decide, sign and lodge your own response
Why it matters
A section 167 notice is compulsory. It is not a finding that you have done anything wrong, but not complying is an offence and a civil penalty matter. Your response has to describe accurately what your agency does, whichever side of the line you are on.
How this works for you
We review your documents and do the non-legal work: the services review, the response map, the records index and chronology, and your enrolment details. If your situation needs a lawyer, we tell you. Because our work is with law firms, we know the firms that specialise in AML/CTF, and we can point you to one. You decide, sign and lodge your own response.
The services AUSTRAC is asking about
Tranche 2 is about the services an agency provides. Services that can bring an agency in include:
- Acting on the sale or purchase of real estate, for the seller or the buyer
- Buyer's agent services
- Arranging the transfer of an interest in real estate
Property management and leasing are treated differently from sales. If your agency does both, the review shows which parts of your business are in and which are not.
What can be included
Notice breakdown
Each item AUSTRAC requires, the deadline and the form of response, in plain language.
Designated services review
A factual map of your agency's services against the Tranche 2 designated services. Each service is marked as appearing to fall within, appearing to fall outside, or unclear, with legal advice recommended.
Response map
For each item in the notice: what it asks for, which facts and records answer it, and where those records sit. We do not draft your answers.
Records index and chronology
Built from the records you supply. Each record is indexed against the notice item it answers, with a dated chronology of what existed before the notice and what has been done since.
Fact pack, if you do not provide designated services
If you conclude you are outside the regime, the facts and records that support that position, organised for your response.
Enrolment details and next steps, if you do
Your enrolment details prepared for you to lodge, the dates that follow (including notifying AUSTRAC of your compliance officer within 14 days of enrolling), and a one-page roadmap for your AML/CTF program, risk assessment and customer due diligence.
Who does what
Your agency
- Reads the notice and decides how to respond
- Decides whether it provides designated services
- Collects the records the notice asks for
- Decides what is disclosed and any privilege question, and lodges AUSTRAC's privilege form within the notice period if needed
- Writes, signs and lodges the response
- Deals with AUSTRAC
JurisIT
- Breaks down the notice: each item, the deadline and the form of response
- Reviews your services against the designated services
- Prepares the response map
- Builds the records index and chronology from what you supply
- Prepares your enrolment details, if you need to enrol
- Sets out your next steps and the dates that follow
- Tells you if you need a lawyer, and who specialises in AML/CTF
Nothing is backdated. The chronology shows what existed before the notice and what has been done since, with dates. An accurate picture of where you stood, and where you now stand, is the strongest position to respond from.
When you need a lawyer
Some situations need legal advice before you respond:
- You have provided designated services without being enrolled since 1 July 2026
- It is unclear whether a service is a designated service
- The notice asks for material you consider privileged
- AUSTRAC follow-up suggests an investigation
We will tell you if any of these apply, and point you to a law firm that specialises in AML/CTF. Legal advice is outside our fixed fee.
Outside the fixed fee
- Notices that ask for AML/CTF program records, customer due diligence files or transaction data (quoted separately)
- More than one entity (quoted separately)
- Collecting records on your behalf
- Drafting, settling or lodging your response
- Legal advice, or representation before AUSTRAC
- AML Program Setup, which is a separate engagement
The fixed fee covers one entity and one round of written queries. The seven business days start when your intake is complete.
Short deadline?
If your deadline is less than seven business days away, say so in the form. We will confirm case by case what can be done in the time available.
Your data
Your notice and records are received through a secure upload, not email, and held in Microsoft's Australian cloud region.
Request your fixed-fee quote
Complete the form and we will contact you within one business day to confirm your fixed fee and next steps. Please do not send the notice itself; we will arrange a secure way to receive it.
Frequently Asked Questions
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No. It is a compulsory information-gathering notice, not a finding that you have contravened the law. Not complying with it is an offence and a civil penalty matter, so the real risk is ignoring it or answering inaccurately.
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No. We prepare the notice breakdown, services review, response map, records index and chronology. Your agency writes, signs and lodges the response.
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We will tell you, and say why. Because our work is with law firms, we know the firms that specialise in AML/CTF and can point you to one. Any legal advice is between you and that firm, and outside our fixed fee.
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You receive a fact pack setting out the facts and records that support that position, organised for your response. An accurate description of what you do matters, because being treated as regulated brings ongoing obligations.
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We prepare your enrolment details for you to lodge, set out the dates that follow and give you a roadmap for your program. If you have provided designated services without being enrolled since 1 July 2026, we recommend legal advice before you respond.
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A fixed fee, confirmed when we contact you and paid before work starts. Complete the form and we will come back to you with the fee within one business day.
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No. Complete the form with the date of the notice and your deadline, and we will arrange a secure way to receive it.
JurisIT provides compliance and document preparation services. It does not give legal advice on the notice, its validity or privilege, and does not represent you before AUSTRAC. Where legal advice is needed, we tell you and can point you to a law firm that specialises in AML/CTF.