Curlew Comply
AML/CTF & AUSTRAC compliance, made simple for Australian reporting entities.
Since 1 July 2026, Australian real estate agents, accountants and conveyancers are reporting entities under the AUSTRAC tranche-2 AML/CTF regime. Curlew Comply is the software that helps your business build and run its program — enrolment, risk assessment, customer due diligence, reporting, and audit trail — in one place.
AML/CTF Comply is now Curlew Comply — same AUSTRAC compliance software, new name.
The AUSTRAC regime is live — commenced 1 July 2026 · Real estate, accountants, lawyers, conveyancers, trust & company service providers must now be enrolled and operating an AML/CTF program.
The biggest compliance change in 18 years landed on 1 July 2026.
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 brings real estate, accountants, lawyers, conveyancers, and trust & company service providers into the AUSTRAC regime for the first time. Since 1 July 2026, anyone providing a designated service under Table 5 or Table 6 of the Act must be enrolled with AUSTRAC and operating a full AML/CTF program — or stop providing the service.
This is not optional, not a phased recommendation, and not waiting for further consultation. The Act is compiled, the Rules are published, and the regime is in force.
We built Curlew Comply (formerly AML/CTF Comply) because the businesses now in scope — agencies, accounting firms, conveyancers — don't have years to build internal compliance programs from scratch. They need a working program now. Comply is how you get there.
Who's caught
Who's caught by the new regime?
If you provide any of these designated services in the course of carrying on a business, you must be enrolled with AUSTRAC and operating an AML/CTF program — that obligation commenced on 1 July 2026.
Real estate agents
Table 5, Item 1
Brokering the sale, purchase, or transfer of real estate on behalf of a buyer, seller, or transferor. Includes every agency principal and every licensee in charge.
Property developers
Table 5, Item 2
Selling or transferring real estate in the course of carrying on a business, where the sale is not brokered by an independent real estate agent.
Accountants
Table 6, Items 1–7
Qualified accountants (CPA Australia, CA ANZ, IPA) assisting clients with real estate transactions, body corporate transactions, equity/debt financing, or company restructuring.
Lawyers, conveyancers & TCSPs
Table 6, Items 1–7
Legal practitioners, conveyancers, and trust & company service providers undertaking the same designated services. Includes anyone managing client money as part of a transaction.
Not sure if you're caught? Check with AUSTRAC's eligibility tool →
The obligations
17 obligations. One platform.
The AML/CTF Act and Rules 2025 set out 17 distinct obligations. Curlew Comply covers every one of them.
AUSTRAC enrolment
Enrol on the Reporting Entities Roll before providing any designated service
Dashboard reminders + compliance calendar
ML/TF risk assessment
Document and review the money-laundering and terrorism-financing risks your business faces
Risk Assessment module
AML/CTF policies & program
Maintain a documented compliance program and apply it consistently
Policy & Process Docs module
Designated compliance officer
Name a specific individual responsible for AML/CTF compliance
Personnel module
Governing body oversight
Board / directors / sole owner must oversee compliance and receive annual reports
Personnel + Reporting modules
Personnel due diligence
Verify and re-verify personnel in AML/CTF roles before and during employment
Personnel module
Personnel training
Train all relevant staff on AML/CTF obligations, tailored to their role
Personnel module
Initial customer due diligence
Identify and verify every customer before (or upon) providing a designated service
Customer CDD module
Ongoing CDD
Track periodic CDD reviews by risk rating, with unusual-activity escalation
Monitoring & Escalation module
Sanctions screening
Screen customers against the DFAT Consolidated List (which incorporates UN Security Council sanctions); record your PEP assessment as part of CDD
Customer CDD module
Suspicious matter reports (SMRs)
Report suspicions to AUSTRAC within 24 hours (terrorism) or 3 business days
Reporting module
Threshold transaction reports (TTRs)
Report any physical-cash transaction of $10,000 or more
Reporting module
Cross-border movement reports
Report cross-border physical currency or bearer-negotiable instruments of $10,000+
Reporting module
7-year record retention
Retain records and reports for at least 7 years
Structured records + 7-year audit log
Independent evaluation
Periodic independent evaluation of the program's effectiveness
Program Maintenance module
Effectiveness checks
Periodic testing that each part of the program is actually working
Program Maintenance module
Tipping-off prevention
Never inform a customer that an SMR has been made or is contemplated
Built into UI workflows
Citations: AML/CTF Act 2006 (Compilation No. 60, 31 March 2026); AML/CTF Rules 2025 (Compilation No. 1, 31 March 2026).
Inside Comply
What's inside Curlew Comply
Nine purpose-built modules. Every form pre-built. Every obligation tracked.
Risk Assessment
Pre-built real estate risk assessment matching the AUSTRAC starter kit. Customisable per business. Country risk table pre-populated.
Policy & Process Docs
Auto-generated, pre-filled policy and process documents.
Personnel
Role assignment, compliance officer designation, personnel due diligence (PDD) forms, training tracker, annual review reminders.
Customer CDD
Onboarding and CDD forms for every customer type — Individual, Sole Trader, Body Corporate, Partnership, Trust, Government Body. Risk rating calculator built in.
Monitoring & Escalation
Unusual activity reporting, escalation to compliance officer, enhanced CDD workflow, periodic review reminders by risk band.
Reporting
SMR workflow (24-hour and 3-day timers), TTR capture, CBMR, annual compliance report generator. Submission tracking and audit trail.
Program Maintenance
Periodic reviews, independent evaluation scheduler, effectiveness checks, governing body report generator.
Document Generator
Auto-generate AUSTRAC-formatted, pre-filled Word versions of every required document. One click.
Dashboard & Audit Trail
Compliance health score, deadline calendar, 7-year audit log, full export capability for inspections and audits.
Curlew Comply prepares and tracks reports; you lodge them yourself through AUSTRAC Online.
Why Comply
Why Curlew Comply, not a generic compliance product
Built to the Act, not adapted from another jurisdiction
Comply is built from the Australian AML/CTF Act 2006 and Rules 2025 directly. Not a US BSA tool adapted for Australia, not a UK MLR tool retro-fitted, not a generic KYC platform with an Australian skin. Every form, every workflow, every retention rule maps to the Australian law.
AUSTRAC starter-kit aligned
Every form in Comply mirrors the AUSTRAC starter-kit templates. If your inspector or auditor recognises the format, they recognise it because it's the format AUSTRAC publishes.
Designed for the firms now in scope
We didn't build this for major banks. We built it for the real estate agencies, accounting firms, and conveyancers who are being brought into the regime for the first time — and who don't have a 50-person compliance department to lean on.
Australian-hosted, Australian-built
Hosted on Microsoft Azure in the Australia East region (Sydney). Customer compliance records are stored and processed in Australia. Some supporting services operate overseas — including Stripe, which processes subscription billing — as disclosed in our Privacy Policy. Built by an Australian team that's actually read the Act.
Pricing
Three tiers. Australian dollars. Per month.
solo agent / small firm
Starter
From $79/month
- 1 user
- Up to 100 active customer records
- All document generators
- Sanctions screening (DFAT Consolidated List)
- SMR/TTR workflow
- Compliance dashboard
agency / multi-agent firm
Business
From $149/month
- Up to 10 users
- Unlimited active customer records
- All document generators
- SMR/TTR/CBMR workflow
- Annual compliance report generator
- Sanctions screening included
group / franchisor / large firm
Enterprise
Custompricing
- Unlimited users
- Unlimited active customer records
- Sanctions screening included
- Talk to us about white-label and API
- Dedicated implementation support
Pricing is indicative and may change. Start with a 14-day free trial.
FAQs
The questions we keep getting
Curlew Comply is a software tool. It does not provide AML/CTF advice. Regulatory questions should be directed to AUSTRAC or to your own adviser.
The regime is live. Get your AML/CTF program running — without building it from scratch.
Start your 14-day free trial of Curlew Comply (formerly AML/CTF Comply). A pre-built risk assessment, every document generator, and the reminders and audit trail you need to get your program operating.
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