AMLHQ Capabilities

Purpose-Built for Australian Real Estate

AMLHQ was designed around the practical workflow of a real estate transaction. That means the compliance framework considers vendors, purchasers, agency appointments, contracts of sale, property ownership, companies, trusts, SMSFs, beneficial owners, source of funds, third-party payers, PEPs, unusual transaction behaviour, cash, offshore funds and transaction-specific risk.

SENTINEL is not a generic financial-services platform adapted with a real-estate skin. It was designed around the people, documents, transactions and decisions that exist inside an Australian real estate agency.

ML/TF Risk Assessment & AML/CTF Program Development

AMLHQ assists agencies with developing their foundational AML/CTF compliance program, including:

• Agency-specific Money Laundering/Terrorism Financing (ML/TF) risk assessment
• AML/CTF policies tailored to the agency's structure and risk profile
• Documented procedures and controls
• Systems implementation
• Program governance and approval
• Version history and evidence of updates
• Regular program review and evolution

AMLHQ creates the actual agency program during onboarding — this is not a template exercise. The program reflects the agency's specific ML/TF risks, transaction types, customer profile and operational structure.

Named Human Compliance Officer

Under AMLHQ's CO, Hybrid and CFO Models, an agency can be assigned a human Compliance Officer to provide professional oversight of its AML/CTF framework. The Compliance Officer can:

• Review escalated or higher-risk files
• Assess complex customer and ownership structures
• Review unusual activity
• Guide enhanced customer due diligence
• Manage compliance escalations
• Support SMR and TTR obligations
• Document compliance reasoning and decisions

The important distinction: Software can identify information and risk indicators. Human judgement determines what those indicators mean and what should happen next.

SENTINEL Compliance Platform

SENTINEL is AMLHQ's purpose-built AML/CTF compliance platform for real estate. It provides role-based access for agents, Compliance Officers, principals, administrators, and group/head office users. SENTINEL is designed to create a structured compliance record from customer onboarding through to final compliance review.

SENTINEL connects the entire AML/CTF compliance lifecycle — risk assessment, customer onboarding, transaction assessment, ongoing monitoring, reporting, and seven-year record retention — into a single, integrated system.

Customer Due Diligence & GreenID Integration

SENTINEL integrates GreenID for digital identity verification. Customers can complete identity verification digitally, while SENTINEL records the verification outcome against the compliance file.

The relationship: GreenID provides identity verification and data validation → SENTINEL brings that information into the AML compliance file → SENTINEL's AI assists with entity and document analysis → The Compliance Officer makes the final risk and compliance determination.

Important: GreenID is AMLHQ's technology choice. AUSTRAC does not mandate the use of GreenID specifically. AMLHQ uses identity technology as one part of CDD rather than treating identity verification as the entire AML process.

KYB, Companies, Trusts, International Entities & Beneficial Ownership

AMLHQ supports complete Know Your Business (KYB) analysis for:

• Australian registered companies and corporate structures
• Trusts (discretionary, unit, charitable)
• Corporate trustees and trustee identification
• Self-Managed Super Funds (SMSFs)
• Partnerships and joint ownership structures
• International entities and offshore ownership structures
• Ultimate Beneficial Owners (UBOs)
• Natural persons exercising control (not just listed directors)

International KYB approach: Software cannot reliably verify international business structures — foreign registries aren't standardized, beneficial ownership is often hidden by design, and risk assessment requires human judgment. AMLHQ's Compliance Officer systematically investigates international entities using public sources, documents what they find and what they can't verify, and makes defensible decisions.

AI-Assisted Compliance — Human Decision

AMLHQ uses AI to assist Compliance Officers with analysis. AI can support risk assessment, identification of anomalies, analysis of complex entity information, pattern recognition, and preparation of compliance summaries.

AMLHQ operates a human-in-the-loop model. AI does not replace the Compliance Officer. Technology finds the signal. A human decides what it means.

PEP, Sanctions & Higher-Risk Matters

SENTINEL supports screening and escalation for matters involving Politically Exposed Persons, sanctions, higher-risk jurisdictions, offshore funds, unusual transaction behaviour, third-party payments, complex structures, and source-of-funds concerns.

Where risk increases, the file can be escalated for Compliance Officer review and additional CDD.

Automated Transaction Assessment & Risk-Based Ongoing Monitoring

Automated Assessment: Every transaction entered into SENTINEL is automatically assessed against the agency's AML risk framework and transaction-specific risk indicators.

Transaction Risk Levels:

• Green → Proceed normally
• Amber → Request further information, Compliance Officer review
• Red → Stop transaction, escalate immediately, enhanced CDD required

Ongoing Monitoring: AMLHQ applies risk-based monitoring appropriate to real estate, identifying relevant changes in customer, transaction or risk profile during the business relationship — such as changes in source of funds, new third-party payers, changes in ownership structure, unexpected offshore involvement, or unusual instructions. Monitoring is proportionate to risk, not bureaucracy for bureaucracy's sake.

Suspicious Matter & Threshold Transaction Workflows

SENTINEL supports Compliance Officers in managing regulatory reporting workflows. This includes identification and escalation of suspicious activity, recording when reasonable suspicion was formed, SMR deadline management, TTR threshold alerts, and audit evidence collection.

Final regulatory reporting decisions remain the responsibility of appropriately authorised people within the reporting entity's compliance framework.

Compliance Records & Audit Trail

SENTINEL is designed to retain evidence of what happened on a compliance file — not simply the final result. Records can show who submitted information, who reviewed the file, risk assessment outcomes, supporting documents, escalations, Compliance Officer decisions, decision rationale, status changes, dates and timestamps, and regulatory reporting activity.

AMLHQ's objective is to make the compliance history reconstructable and defensible. A risk rating without the evidence and reasoning behind it is not enough.

Seven-Year Record Retention

SENTINEL supports the long-term retention of AML/CTF compliance records consistent with applicable AML/CTF record-keeping obligations. AMLHQ's compliance architecture is designed around seven-year retention requirements applying to relevant AML/CTF records.

Records are immutable, timestamped and audit-logged to provide irrefutable evidence of compliance activity.

Compliance Reporting & Governance

SENTINEL is designed to turn archived compliance activity into meaningful governance reporting. Reporting can draw from CDD activity, customer risk ratings, higher-risk cases, beneficial ownership matters, PEP and sanctions matters, enhanced CDD, ongoing monitoring, Compliance Officer escalations, SMRs and TTRs, staff training, and program reviews.

The objective is to give principals, governing bodies and Compliance Officers a clear view of whether the AML/CTF framework is actually working.

Independent Evaluation Readiness

AUSTRAC requires AML/CTF programs to undergo independent evaluation. SENTINEL is designed to maintain the evidence an appropriately independent evaluator may need to examine, including the ML/TF risk assessment, AML/CTF policies, customer files, CDD records, transaction records, monitoring activity, Compliance Officer decisions, and training records.

The aim is to be evaluation-ready before the evaluator arrives.

Personnel Due Diligence (PDD) & Know Your Employee (KYE)

AMLHQ recognises that effective AML compliance requires understanding the people delivering it. SENTINEL supports comprehensive personnel due diligence and Know Your Employee processes, including:

• Identification of personnel performing AML functions
• AML role classification (Compliance Officer, checker, approver, etc.)
• Personnel due diligence records
• Competency assessments
• Integrity and fit-and-proper assessments
• Relevant background information
• Training status and completion records
• Reassessment and review dates
• Compliance issues and remediation tracking
• Compliance Officer oversight
• Time-stamped evidence of PDD activity

This creates a personnel compliance record that demonstrates your agency understands who is responsible for AML compliance and has assessed their capability and integrity.

Real Estate AML Training, Competency & Continuing Education

AMLHQ's training framework is supported through Better Business Coach and AMLHQ's real-estate compliance expertise. Training includes:

• Initial AML education for new personnel
• Role-specific training (agents, compliance checkers, principals, Compliance Officers)
• Compliance Officer education and professional development
• Competency assessment and testing
• Refresher training and ongoing updates
• Continuing education aligned with regulatory developments

AMLHQ employs experienced AML training consultants like Trish Johnson to design, deliver and contribute to AMLHQ's Continuing Education program. This creates an authority chain: AMLHQ → training → real person → professional AML experience.

SENTINEL can maintain records of training assigned, training completed, course or module, completion date, assessment result, and outstanding training, creating a live training status dashboard for the agency.

Hybrid Model — Keep Your Existing AML Software

AMLHQ does not require every agency to abandon technology it has already purchased. The Hybrid Model allows an agency to retain its existing AML or VOI platform while adding the human Compliance Officer and governance layer.

The proposition is simple: Keep the software. Add the judgement layer.

Group & Franchise Compliance

AMLHQ provides a group-level compliance model for multi-office businesses and franchise networks. The objective is to allow head office or group leadership to identify office-level compliance status, systemic weaknesses, training gaps, higher-risk matters, and compliance trends across the network.

Individual offices can retain appropriate independence while group leadership gains greater visibility over systemic AML/CTF risk.

Business Advisory Support

AMLHQ's compliance models were developed with input from Certified Professional Business Advisors and real estate industry professionals. This matters because compliance affects people, workflow, management, customer experience, risk, cost, leadership time and business performance.

AMLHQ therefore approaches AML/CTF compliance as both a regulatory and operational business issue.

Compliance Cost-Recovery Methodology

AMLHQ provides agencies with a commercial methodology for considering whether AML compliance costs can be recovered through existing or appropriately structured vendor administration charges.

The objective is straightforward: Better compliance does not automatically have to mean higher net overhead.

CFO Model — Compliance + Finance

For agencies without an existing finance business, AMLHQ offers an optional Compliance & Finance Officer Model. The model combines AML compliance support with a finance capability delivered through EZFinance Pty Ltd, Australian Credit Licence 392611.

Its purpose is to allow an agency to establish a finance revenue stream while maintaining AML compliance support.

Security & Australian Data Hosting

AMLHQ/SENTINEL is built on infrastructure supplied by providers holding SOC 2 and ISO 27001 certification:

Additional controls include encrypted data transmission and storage, role-based access, audit logging, session controls, two-factor authentication across all portals, malware and security controls, and Australian data hosting.