# Personnel Due Diligence for Real Estate Agencies Most agencies think about AUSTRAC obligations in terms of clients: screening buyers, verifying vendors, checking a company's beneficial owners. AUSTRAC's AML/CTF Program guidance also requires something agencies overlook far more often — personnel due diligence (PDD) on their own staff. This article is general information, not legal advice. Your agency remains responsible for its AML/CTF Program, including how it designs and applies personnel due diligence. ## The short answer: it covers more people than you'd think, and it never really finishes Personnel due diligence applies to anyone your agency employs or engages to perform a function relevant to its AML/CTF obligations — not only the agents who face clients. That includes administrative staff, contractors, and anyone with a role that touches customer due diligence, reporting, record-keeping or program governance. AUSTRAC's guidance is explicit that this covers "all your personnel such as administrative staff as well as real estate agents." It is also not a one-off hiring check. AUSTRAC's AML/CTF Program guidance requires personnel due diligence before you employ or engage someone in an AML/CTF-relevant role, and on an ongoing basis throughout their employment or engagement. ## What AUSTRAC's own example shows AUSTRAC has published a worked example of poor practice, using a hypothetical real estate agency it calls "Poor Practice Realty." The agency had a personnel due diligence policy on paper, but it was generic — it didn't tailor checks to the risk of each role. New hires went through an interview, reference checks and a self-attestation form, but staff who processed high-value property transactions received no further screening: no background or criminal history checks, no assessment of prior AML/CTF experience. The agency only discovered a staff member's links to a criminal organisation when that person was arrested — and a review afterward found they had processed a series of suspicious cash property transactions. AUSTRAC's own conclusion is worth quoting directly: by failing to meet its personnel due diligence obligations, the agency "hired a personnel member with previous criminal connections that facilitated suspected money laundering activity." It's a regulator-authored hypothetical, not a real business — but it is squarely aimed at agencies exactly like the ones reading this. ## Identify your high-risk roles first AUSTRAC expects agencies to map out which roles are relevant to their AML/CTF obligations, then identify which of those roles carry higher risk and deserve more thorough checks. A role is more likely to be high-risk if the person can: - authorise or submit reports to AUSTRAC, including suspicious matter reports and threshold transaction reports; - override or bypass internal controls; - handle high-value transactions or physical currency (cash); - approve or escalate high-risk customers, or amend a customer's risk profile; - design or influence changes to the agency's AML/CTF policies; or - access highly sensitive customer or business information. A customer-facing staff member who only helps a client complete an onboarding form needs much lighter due diligence than an AML/CTF compliance officer who oversees the whole program. The level of checking should match the role, not be a single standard form for everyone. ## What to check, before and during employment For each relevant role, AUSTRAC expects an agency to assess two things: skills, knowledge and expertise, and integrity. Skills and knowledge checks can include interviews, knowledge-based assessment, validating qualifications, or checking prior AML/CTF experience. Integrity checks — tailored to the risk of the role — can include identity verification, police checks, bankruptcy checks, sanctions and adverse media screening, and reference checks. Due diligence doesn't stop at the hiring decision. AUSTRAC expects ongoing reassessment, particularly when something changes: a promotion into a higher-risk role, a shift in the agency's risk profile (such as offering a new high-risk service), or a change in the person's own circumstances — for example a criminal investigation, a significant change in financial arrangements, or a new conflict of interest. ## Keep the record, not just the check AUSTRAC requires agencies to keep records that demonstrate compliance with personnel due diligence obligations — not just that a check happened, but what was checked, when, and what was found. That can include qualification and certification records, interview and reference-check outcomes, integrity assessment results, and a documented audit trail of the decisions made for each person. If a check turns up something concerning, the record should also show what the agency did about it — closer monitoring, reassigning duties, additional training, or removing someone from AML/CTF functions altogether. ## Where AMLHive fits AMLHive's Employee Screening feature covers one specific item on AUSTRAC's integrity-check list: before an agent's account can be activated, AMLHive screens them against sanctions and adverse media data, and re-screens automatically every year afterward. A clean result is required before the account goes live, and the screening result is stored for the agency's records. That is one input into personnel due diligence, not the whole obligation. AMLHive does not assess skills, knowledge or AML/CTF expertise, run police or bankruptcy checks, conduct reference checks, deliver training, or decide whether a role is high-risk. Those judgements, and the wider personnel due diligence program, remain the agency's responsibility. For more on the program this obligation sits inside, see [After 1 July: Running Your Real Estate AML/CTF Program](/Compliance/compliance-blog/real-estate-amlctf-program-after-1-july). For the compliance officer role specifically, see [AML/CTF Compliance Officer for Real Estate](/Compliance/compliance-blog/compliance-officer-myth). The habit worth building is simple: map the roles, match the checks to the risk, and keep the evidence current — not just at hiring, but for as long as someone holds an AML/CTF-relevant role. ## Sources - [AUSTRAC: Personnel due diligence (PDD)](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/personnel-due-diligence-and-training/personnel-due-diligence-pdd) - [AUSTRAC: Identifying personnel roles that require due diligence and training](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/personnel-due-diligence-and-training/identifying-personnel-roles-require-due-diligence-and-training) - [AUSTRAC: Examples of personnel due diligence and training in practice](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/personnel-due-diligence-and-training/examples-personnel-due-diligence-and-training-practice)