What changes
- Money received into trust in connection with a sale is part of a designated service.
- Physical cash of AU$10,000 or more received into trust triggers a threshold transaction report within 10 business days.
- Unusual movements through trust are a classic trigger for a suspicious matter report.
What does not change
State trust account rules, audits and receipting continue as before. AML records sit alongside them; they do not replace them.
Practical policy
Most small agencies decide not to accept cash into trust at all, state it in the program and never lodge a TTR. If you accept cash, log every transaction the day it happens.
Questions people ask
- Does the trust account auditor check AML compliance?
- The trust account audit is a state requirement and looks at trust records. AUSTRAC is the AML regulator. Keep both sets of records complete.
This guide is general information for real estate agents, buyers agents, property managers, not legal advice. Check AUSTRAC's current guidance for your situation.