AML/CTF Operational Readiness · Australian Real Estate · Obligations Live 1 July 2026

AML/CTF obligations are live.
Most businesses enrolled. Far fewer have a system their team actually follows.

Ready by Design builds the operational readiness system that sits behind your verification platform — your process documented, your team trained, your workflows rebuilt around how your business actually works, and your program ready for your principal or director to approve and go live.

⚠ Obligations are now live. AUSTRAC can review your program, your training records and your CDD decisions at any time. A verification platform is not an AML/CTF program.
Fixed price  ·  Not legal advice  ·  General operational readiness support only  ·  Australia-wide  ·  Based in QLD
Status
Obligations Live
AML/CTF Act obligations commenced 1 July 2026 for newly regulated real estate entities.
1 Jul 2026
AML/CTF obligations commence
for newly regulated real estate entities
29 Jul 2026
Final deadline to enrol
with AUSTRAC as a reporting entity
30 Sep 2027
First annual compliance
report due to AUSTRAC
Who I work with

Built for the businesses
that can't afford to get this wrong.

01
Solo Licensed Real Estate Agents

You operate independently with no ops team to figure this out. You need a simple, practical system built around your process, your buyer types, and your day-to-day reality — not a generic template.

02
Small to Medium Real Estate Agencies

You have a team, a CRM and an existing sales process. What you don't have is a clear picture of what needs to change, who owns each step, and how to train your staff to follow it consistently.

03
Property Developers, Project Marketers & Land Estates

You sell direct — boutique developer, project marketer or land estate operator. Your in-house sales team manages the buyer relationship from enquiry to settlement across multiple projects, and every handoff point is now a compliance checkpoint.

04
You Missed the Deadline — or Enrolled Without a Program

Enrolment is not a program. A downloaded template is not a system. If your team hasn't been trained, your CDD process isn't documented, or you simply haven't started — you're exposed right now. The faster you move, the better your position.

05
You Need Ongoing Compliance Support

Your program is live but compliance doesn't stop at go-live. Staff change, processes evolve, AUSTRAC updates guidance. Retainer support keeps your system current, your team trained, and your records organised and up to date.

Who I am

Xiomara Hewat

Operational Systems Consultant — AML/CTF Readiness
Australia-wide  ·  Based in QLD

I turn complexity into clarity and anxiety into structure. Where most people see new legislation and freeze — I build the checklist, the process, the workflow and the training plan. I think like someone who understands both the frontline sales reality and the director-level risk environment. I hold both at once — and build the system that connects them.

15+
Years in regulated
operating environments
3
States — QLD, NSW, VIC
active project marketing
MBA
+ BSc · Cert IV Training
& Assessment
View LinkedIn
Operational readiness support — not legal advice

I get inside your business.
Then I build the system.

Most businesses don't struggle with AML/CTF obligations because they ignored the rules. They struggle because nobody translated the rules into the way their team actually works — the CRM stages, the EOI handoffs, the foreign buyer who needs FIRB flagged before contract, the trust purchaser nobody thought to verify.

I design the operating rhythm that allows a real estate business to move through regulatory change without losing momentum. I map your existing process, identify every gap, rebuild your workflows with compliance embedded at every decision point, make CRM field recommendations, train your team, and guide implementation from start to finish — delivering a complete program your principal, director or senior manager approves and your team goes live with.

"I'm here, I'm living it, I've implemented it — and I'm here to help you."
Fixed price — no hourly billing
Every engagement is scoped and priced before work begins. No surprises. No scope creep.
Built around how you actually work
Not a generic template. A readiness system designed around your team, your process and your buyer types.
Ready to approve and go live
I deliver the complete operational readiness pack. AUSTRAC requires sign-off from your principal, director or senior manager — not a lawyer. You implement with confidence.
Staff training included — in plain English
Scenario-based. Role-specific. Designed for sales consultants — not compliance officers.
Support before, during and after delivery
You're not alone after handover. Questions, adjustments and escalations throughout your support window.
A working system — not a reading list
When we're done, your team knows what to do at every stage of a sale. The documents exist because the system works — not the other way around.

How it works

1
Map
I review how your business actually works — your sales process, your buyer types, your team structure and your current gaps. This is the foundation everything else is built on.
2
Build
I redesign your sales process with compliance embedded at every decision point — your risk assessment, policy, CDD workflow, updated forms and CRM fields. Built around your business, not a generic standard.
3
Train
Your team learns what to do — and what to do when something doesn't feel right. Plain English, scenario-based, signed off. No compliance jargon, no reading homework.
4
Embed
You walk away with a working system. Your principal or director approves and goes live. Your team follows the process. Compliance becomes part of how you sell — not something separate to manage.
Software references, including PEXA Clear or CRM tools, are general workflow recommendations only. Ready by Design is not affiliated with these providers, receives no commission or referral fee, and does not set up or manage third-party software. Clients remain responsible for selecting, paying for, configuring and managing their own software systems.
What Ready by Design builds

Six deliverables.
One complete readiness system.

Draft AML/CTF Program

Your written policy document, tailored to your business structure, buyer types and sales process. Ready for review and approval by your principal, director or senior manager.

ML/TF Risk Assessment

A documented risk assessment covering your services, client types, geographies and delivery channels — aligned to AUSTRAC's risk-based approach.

Updated Sales Process Map

Your existing sales workflow rebuilt with AML/CTF obligations embedded at every stage — from first enquiry through to settlement. Role-specific. Plain English.

CDD & Escalation Workflow

Step-by-step customer due diligence procedures including verification triggers, enhanced due diligence pathways, and escalation steps for higher-risk matters.

CRM Field Recommendations

Practical recommendations for updating your CRM to capture and record the right information at the right stage of each transaction — built around how your team actually uses the system.

Staff Training & Implementation Plan

Scenario-based training written for sales consultants, not compliance officers. Includes a week-by-week implementation plan, sign-off sheet, and knowledge check.

All documents are provided as drafts for review and approval by the client's appointed AML/CTF Compliance Officer, director, principal or senior manager. Ready by Design does not provide legal advice or regulatory certification.

Three complete programs. Three businesses that went from zero to fully operational.
All staff trained. All directors signed off. All systems live.

Ready by Design — QLD & VIC, 2025–2026  ·  Before this page had a single visitor
Proof of concept

Three complete programs.
Delivered. Live. Done.

Before this page had a single visitor, three complete AML/CTF programs had already been built and delivered — a multi-state project marketing agency, a Queensland property developer, and a solo licensed agent in Melbourne. In every engagement, the full program was built from scratch: risk assessment, policy, process documentation, CRM configuration, staff training delivered in person to the whole team including the CEO and company directors, and sign-off completed. Each business went from zero to a fully operational, documented readiness system.

The deliverables below are what every engagement produces. Built around how each business actually works — not a generic template.

$19,800
Maximum daily penalty
per civil offence (AML/CTF Act)
$6.6M
Maximum civil penalty
per contravention (body corporate)
2 wks
Typical delivery
Essential package

Penalty figures are indicative maximums published under the AML/CTF Act 2006. Actual penalties depend on the nature and frequency of contraventions. This is general information only — not legal advice.

Content is representative only. No client names, specific data or confidential information is shown.

The distinction that matters

A platform verifies your buyers.
I build what the platform sits inside.

AUSTRAC doesn't audit your software subscription. It audits your program — your written policy, your documented process, your staff training records, your CDD decisions. The platform is one tool inside a system. I build the system.

What a platform gives you
  • ✓ Identity verification & KYC checks
  • ✓ PEP and sanctions screening
  • ✓ A risk rating output
  • ✗ Your written AML/CTF Policy
  • ✗ A trained, compliant sales team
  • ✗ A documented program AUSTRAC can review
What I build around it
  • ✓ Risk Assessment & Policy, written for your business
  • ✓ Sales process redesigned with compliance embedded
  • ✓ Staff training your team will actually use
  • ✓ CRM fields and forms updated to match
  • ✓ A complete program ready for your principal or senior manager to approve and go live
  • ✓ Works with whichever verification platform you choose
Fixed scope · Fixed price · Confirmed in writing before work begins

Choose your package.

Three clear packages. Essential and Foundation include the same core build — Foundation scales for more staff, active CRM and multiple projects, and adds a live Zoom session.

Step 0 · Optional
Ready Check
$997
+ GST
Not sure where to start? Begin here.
⏱ 5 business days
  • Pre-session questionnaire
  • 90-minute discovery session
  • Readiness snapshot
  • Gap and priority action list
  • Package recommendation
  • 30-day email Q&A
Fee credited in full toward any package within 30 days.
Book a Ready Check — $997 +
Tier 1 · Solo Agent or Small Team
Essential
$3,800
+ GST
Solo agent or small team · single project · simpler sales process
⏱ 2 weeks delivery
  • Discovery and current process review
  • CDD + PEXA Clear workflow into sales process
  • Updated sales process map
  • Draft AML/CTF Program Pack
  • EOI and internal forms
  • CRM field recommendations
  • Training guide and recorded presentation
  • Implementation plan and 30-day support
50% deposit on signing · balance on delivery
Get started — Essential →

Not sure which package fits? Start with a Ready Check — the $997 + GST fee is credited in full toward any package within 30 days.

Request a Ready Check — $997 + GST →

The honest comparison

Compared to a law firm: Fixed price, full operational build, 30–60 days of support included. Not billed by the hour. Not a document dropped in your inbox.

Compared to compliance software: A platform handles your CDD checks. I build the system it sits inside — your process, your team trained, your program tailored to how you actually sell.

Compared to doing it yourself: AUSTRAC requires your program to be approved by a principal, director or senior manager — not a lawyer. I get you to that point with a complete, structured readiness system, ready for internal approval and go-live.

After Essential or Foundation
Ongoing Retainer
Priced at discovery
Compliance doesn't stop at go-live. Retainer support covers ongoing guidance, annual program review, refresh training, legislative updates, and workflow amendments as your business evolves. Scope and pricing are tailored to your business size and needs — discussed at the end of your Essential or Foundation engagement.

Not a one-size-fits-all subscription. A solo agent and a multi-project developer have very different ongoing needs — and the price reflects that.

Where do you stand right now?

Find out your real readiness score.

Complete the Ready Check questionnaire — approximately 10 minutes. Honest responses help us identify your real gaps. You'll receive your readiness rating and a personalised gap summary by email.

No right or wrong answers. All responses are strictly confidential.

General guidance only. Not a compliance assessment or legal advice.

Ready Check — Pre-Session Questionnaire

Tell us where your business stands.

Complete this before booking your Ready Check. Takes approximately 10 minutes. Honest responses help us identify your real gaps. All information is strictly confidential.

Enter your details to unlock the full questionnaire. We'll email you a copy of your responses and your readiness rating.

Your details are held in strict confidence and used only to prepare your Ready Check session. We do not share your information with third parties. Please do not submit identity documents, AML/CTF records or confidential files through this form.

Section A — Business Structure 1 of 8
Thank you. There are no right or wrong answers — honest responses help us identify your real gaps and deliver the most useful outcome. Starred (★) questions are scored to generate your readiness rating. Submit at the end to receive your rating by email.
A Business Structure
Q1
What is the legal structure of your business?
Q2
How many staff and contractors currently work in your business?
Q3
Which best describes your business activity? (Select all that apply)
Q4
In which states or territories do you currently operate? (Select all that apply)
Q5
Approximately how many property transactions per year?
Q6
Typical property price range?
B AUSTRAC & Compliance Awareness
Q7 ★
Are you aware that your business is required to enrol with AUSTRAC as a reporting entity before 29 July 2026?
Q8 ★
Has your business begun the AUSTRAC enrolment process?
Q9 ★
Has your business appointed a named AML/CTF Compliance Officer?
Q10 ★
Does your business currently have a written AML/CTF Program document in place?
Q11 ★
Has your business completed a Money Laundering / Terrorism Financing (ML/TF) Risk Assessment?
Q12
Are you currently receiving advice from a lawyer or compliance adviser about AML/CTF obligations?
Q12 detail
If yes — briefly describe what they have provided so far
Q13 ★
On a scale of 1–5, how well does your team currently understand AML/CTF obligations?
1 = Not at all5 = Fully understand
C Client Onboarding & Sales Process
Q14
How do most of your buyers currently find you? (Select all that apply)
Q15 ★
At what point do you currently collect buyer information and ID?
Q16
What identity information do you currently collect? (Select all that apply)
Q17
Does your process distinguish between different buyer types? (Select all that apply)
Q18 ★
Do you currently conduct any form of digital identity verification?
Q19 ★
Do you currently screen buyers against sanctions lists or for Politically Exposed Person (PEP) status?
Q20 ★
When a buyer is a company or trust — do you identify the beneficial owners behind the entity?
Q21
At what stage does your EOI process require a deposit, and how is it paid?
D Documentation & Record Keeping
Q22
Where are your current buyer records stored? (Select all that apply)
Q23 ★
Do you currently have a defined document retention policy specifying how long records are kept?
Q24
If a buyer's ID document was collected 2 years ago — where would it be stored today and who could access it?
Q25
Do your current EOI or intake forms capture the following? (Select all that apply)
Q26 ★
On a scale of 1–5, how consistent is your current record keeping across all staff?
1 = Not consistent5 = Fully consistent
E Staff & Training
Q27
Which roles are directly involved in buyer-facing transactions? (Select all that apply)
Q28 ★
Have any of your staff received any AML/CTF awareness training to date?
Q29 ★
If a sales consultant received a cash offer for a deposit today — do they know what to do?
Q30 ★
If a buyer's verification returned a HIGH RISK result — does your team know what to do next?
Q31 ★
Is there a named person in your business responsible for compliance questions, red flags and escalations?
Q31 detail
If yes — what is their name and role?
F CRM & Systems
Q32
What CRM or sales management system does your business currently use?
Q33 ★
Does your current CRM capture any compliance-related fields? (Select all that apply)
Q34
Is your CRM managed in-house or by an external provider?
Q35
Do you use any digital identity verification tool currently?
Q36
What other technology tools are relevant to your sales or compliance process?
G Client & Transaction Risk Profile
Q37
What percentage of your buyers are overseas-based or foreign nationals (approximately)?
Q38
Do you frequently deal with buyers purchasing through trust or company structures?
Q39
Have you ever had a transaction where something felt unusual about the buyer or the funds? (No details required)
Q40
Do any of your projects involve buyers from jurisdictions known for higher ML/TF risk?
H Your Priorities & Concerns
Q41
What is your single biggest concern about AML/CTF compliance right now?
Q42
What outcome do you most want from this Ready Check session? (Select all that apply)
Q43
Is there anything about your business structure, sales process, or client profile that feels particularly complex or unusual?
Q44
Is there anything else you would like us to know before the session?

This rating is based on your self-reported responses and is for general guidance only. It does not constitute a compliance assessment or legal advice. Your detailed gap analysis will be provided during your Ready Check discovery session.

What to expect

How it works.

01
You get in touch
Book a free 30-min discovery call. No commitment — just a conversation to see if we're the right fit.
02
We confirm fit
Ready by Design confirms the right package and scope for your business in writing.
03
Invoice issued
A clear, fixed-price invoice is issued before any work begins. No surprises.
04
Payment received
Work begins once payment is confirmed. Deposit applies for Essential and above.
05
We start building
Questionnaire and booking link sent. Discovery session scheduled. Your system gets built.
Ready to get started?

Book a free discovery call.
Let's talk about where you stand.

The best starting point is a conversation. Email me directly and I'll respond within one business day. No pitch. No pressure. Just an honest discussion about where you stand and what your options are.

xiomara@readybydesign.com.au
Xiomara Hewat  ·  Operational Systems Consultant — AML/CTF Readiness
Ready by Design  ·  readybydesign.com.au  ·  Australia-wide  ·  Based in QLD
ABN: 26 250 635 234  ·  Response within 1 business day
Book a free 30-min discovery call →
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By submitting this form, you agree that Ready by Design may use your details to respond to your enquiry and provide relevant information about our services. Please do not submit identity documents, AML/CTF records, contracts, client files or confidential documents through this form. If documents are required, Ready by Design will provide or agree on an appropriate method for sharing them.