From onboarding your first buyer or seller to managing ongoing checks and reporting - here's how the process works, where Four Foxes fits in, and what it costs at each stage.
Each step below reflects what your AML program requires under AUSTRAC's Tranche 2 obligations for real estate agents. The middle column shows where Four Foxes can support you, and the right column shows indicative costs.
| Step & obligation | How Four Foxes can help | Expected cost |
|---|---|---|
| 1Onboard buyers & sellersCollect and record customer information at the point of engagement, in line with your AML program. | If you don't already have an onboarding workflow, Four Foxes can suggest a practical process that fits how your agency operates - without over-engineering it. | Complimentary |
| 2AML risk assessmentAssess each customer's ML/TF risk as required by your AML Program Risk Assessment before providing services. | If you don't have a risk assessment framework in place, Four Foxes can guide you through building one - covering your program, policy and processes from the ground up. | From $499 Full program setup incl. risk assessment, policy & processes |
| 3Initial Customer Due Diligence (CDD)Perform identity verification on your customer as required under your AML program before or during the transaction. | Log into the Agent Portal, enter the details for the check and send a branded verification link for your customer to complete. You receive the report back with a full audit trail - with a full audit trail to support your records. | $12.50 per KYC check · invoiced monthly |
| 4Enhanced Due Diligence (EDD)Where your program identifies elevated risk, additional information must be collected before proceeding. | Send the request to Four Foxes. We can assist by providing a tailored link for your customer to provide further information and documentation. You receive the compiled report back for your records. | Complimentary |
| 5Escalation & reportingAt any stage, your program may require escalation - internally to senior management or your AMLCO, or externally to AUSTRAC via a Suspicious Matter Report (SMR). | Four Foxes can help prepare factual reports for your AMLCO, governing body or AUSTRAC. The nature of each situation varies, so we'll work through the scope and approach with you. | Depends on scope We'll work it out together |
Four Foxes is developing a complimentary Excel template designed to walk through each AML step sequentially for every customer. It flags when information is missing, keeps your records audit-ready, and replaces what you'd otherwise pay thousands for in an end-to-end compliance platform.
The template will be complimentary when used alongside Four Foxes services - giving smaller agencies the same structure as enterprise tools, without the price tag.
Four Foxes Consulting is here to support and assist your agency - but the responsibility for understanding, implementing and maintaining compliance with all AML/CTF obligations under Australian law rests solely with you as the reporting entity.
The services we provide are intended to assist your compliance efforts and do not constitute legal advice. Our work is one input into your broader compliance framework and should not be relied upon as a substitute for your own due diligence, independent legal advice, or ongoing engagement with AUSTRAC guidance and regulatory updates.
Regulatory requirements may change over time, and it is your responsibility to monitor and respond to any such changes following completion of our engagement. Four Foxes makes no representation or warranty that any AML program we help develop will ensure full compliance with AUSTRAC requirements - compliance depends on factors within your control, including how the program is implemented and maintained day to day.