Australia’s long anticipated AML/CTF tranche 2 reforms are expected to become law by July 2026. This means thousands of more businesses like real estate agencies, accountants and law firms will join the financial sector in taking on the same important AML obligations.
For many businesses this presents a major challenge as they grapple with developing, implementing, and managing compliance requirements alongside their day-to-day business activities.
In this case study we walk through how leading real estate agents, Ray White New Zealand navigated the very same challenges and found a proven path forward with the formation of a Designated Business Group (DBG).
The challenge: Meeting AML obligations with no roadmap
When the New Zealand Anti-Money Laundering and Countering Financing of Terrorism Act took full effect for real estate agencies on 1 January 2019, Ray White, like many other tranche 2 entities, was faced with the very same challenges facing Australian entities right now.
Without any available guidance from the Department of Internal Affairs (DIA), Ray White was operating in a period of uncertainty, lacking clear guidance, and facing the need to implement a fully compliant AML programme under tight time constraints.
Recognising the inefficiencies and risks of going it alone, Ray White made the strategic decision to partner with tic company to create a Designated Business Group (DBG).
The solution: Forming a Designated Business Group
It was initially thought and widely voiced that a DBG would not be approved by the DIA. However, tic company research found parliamentary papers evidencing a ministerial exemption, and it was agreed that the formation of a DBG (also known as a Reporting Group) would benefit all parties including the DIA.
It provided a way for the Ray White network with obligations under AML legislation, to work together using the same processes, documents and systems while being able to rely on other entities in the Group.
Franchises could elect to join the DBG by completing a straightforward application. A subscription-based fee on estimated number of listings payable monthly made costs transparent and affordable for franchises, and covered all aspects of AML outsourced to tic company such as:
- Conducting all levels of customer due diligence (CDD)
- Creation of Ray White’s AML compliance programme and risk assessment documentation
- Access to Tic’s trusted AML software
- Annual reporting and independent audit support
- Record keeping
- Expert advice and ongoing help
- Staff vetting
- AML training and coaching of existing and new members
The benefits: Centralisation, cost savings, and compliance confidence
While the option of outsourcing AML activities to tic company without forming a DBG came under consideration, Ray White felt the DBG approach would suit their franchise structure and deliver immediate and lasting benefits:
- Cost effective: The DBG provides lower costs than internal options or external competitors, with the flexibility of varying models that supports the business and provides full transparency.
- Speed and accuracy: Most cases are turned around very quickly and more complicated cases are supported by the tic company team with personal contact made where necessary. This results in a low incidence of delays or exceptions.
- Support for complex cases: On-the-ground services and personalised support are on-hand for challenging verifications.
- Savings without compromise: The DBG AML solution remains more affordable than comparable options without compromising on quality.
- Streamlined audits: Independent audits are carried out on the DBG collectively rather than on each individual office, providing significant cost savings, reducing complexity and the burden on individual offices.
- Standardised compliance: Centralised processes and systems mean minimal duplication across offices and the maintenance of standards.
- Real-time visibility: The online portal – AMLify, provides full visibility with a cross-network view of records for compliance officers and senior leadership to view.
“The DBG significantly reduced the reputational and compliance risks to the Ray White brand. The flat fee removes the incentive to avoid CDD and the centralised approach provided common standards across the network.”
Treena Drinnan, Chief Agency Officer
The results: Regulatory and operational success
Ray White NZ’s decision to partner with tic company to create an expert AML outsourcing solution in the form of a Designated Business Group not only created a cost-effective solution but also created a practical and regulator approved path forward.
A solution that has been embraced by approx. 200 offices and hundreds of members creating the largest DBG in NZ real estate, and commended by the DIA as a best practice entity that provides a model for others in the real estate industry to meet.
A strategic head start for Australia’s tranche 2 businesses
With AML/CTF obligations set to apply to tranche 2 entities from 1 July 2026 now’s the time for Australian tranche 2 businesses to take control of their AML obligations.
The Ray White model developed with tic company provides a blueprint for a compliant solution. The model helped lower costs, save time, alleviate complexity, and reduce risk; however, it’s not the only solution which can provide some of these benefits. If you are a standalone business, or are not ready to create a centralised approach across your network, a collaborative or fully outsourced solution may be an option for you.
Whether you opt to form a DBG (or Reporting Group), join one, outsource compliance activity, or simply require access to trusted AML software, working with tic company ensures you’re not alone in dealing with your AML obligations.
Call us on 09 369 6867 to discuss what option could work for you or email info@ticcompany.com
For more real-life case studies, see how law firm Hamilton Locke NZ gained peace of mind. and ensured they were able to focus on delivering high-quality legal advice without the drag of AML administrative inefficiency or compliance uncertainty. Read Hamilton Locke’s case study: Outsourcing AML: A Smart Move By Law Firm Hamilton Locke NZ
