Industry Training Consultants

Industry Training Consultants NSW CPD approved provider delivering non-accredited real estate training, AML/CTF compliance, and real estate consultancy services.

Helping agencies meet their regulatory obligations with confidence. Industry Training Consultants is a NSW CPD approved provider specialising in non-accredited real estate training, AML/CTF compliance, policy development and regulatory consultancy. We help real estate agencies meet their legislative and professional obligations through practical training and compliance solutions.

AML/CTF Compliance Is Not an ID Check: Why NSW's Supervision Guidelines Need ReviewToday we wrote to NSW Fair Trading to...
17/08/2026

AML/CTF Compliance Is Not an ID Check: Why NSW's Supervision Guidelines Need Review

Today we wrote to NSW Fair Trading to raise concerns about the need to review and update the current Supervision Guidelines to better reflect the AML/CTF obligations now applying to real estate professionals.

As the industry adapts to the new regulatory environment, it is important that guidance provided to licensees aligns with the practical realities of compliance under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

One area that warrants attention is identity verification.

Historically, identity verification has often been approached as a process of collecting and checking a prescribed set of documents. However, AML/CTF compliance requires much more than confirming a person's identity.

The legislation is based on a risk-based approach, requiring reporting entities to assess and manage risks associated with their customers, services, transactions and business operations. Customer due diligence is only one component of a broader compliance framework that also includes:

✔ AML/CTF risk assessments
✔ Ongoing customer due diligence
✔ Transaction monitoring
✔ Suspicious matter reporting
✔ Governance and oversight arrangements
✔ Staff training and compliance programs
✔ Record-keeping obligations

Our concern is that many businesses may still be viewing AML/CTF compliance through the lens of traditional identification procedures rather than the broader risk-management framework required by law.

This creates a risk that licensees may underestimate their obligations or be persuaded by solutions that focus primarily on onboarding and identity verification while overlooking other critical compliance requirements.

As the real estate sector continues to implement AML/CTF reforms, clear and consistent guidance from regulators will be essential to support compliance and protect businesses from unnecessary regulatory exposure.

The conversation should not be about what identification documents are collected. It should be about whether an agency has implemented a compliant AML/CTF program capable of identifying, assessing and managing risk.

Footnote: Real estate professionals providing designated services are reporting entities under the AML/CTF Act. Compliance obligations extend beyond customer identification and include risk assessments, AML/CTF programs, customer due diligence, transaction monitoring, suspicious matter reporting, governance arrangements and ongoing compliance management.

AUSTRAC

🚀 **A New Chapter After 20+ Years**After more than **20 years as a Registered Training Organisation**, our withdrawal of...
14/08/2026

🚀 **A New Chapter After 20+ Years**

After more than **20 years as a Registered Training Organisation**, our withdrawal of registration has now been successfully approved, marking the end of an important chapter in our business journey.

🙏 I would like to take this opportunity to sincerely thank the thousands of students, industry professionals, employers, and agencies who have supported us over the years. Whether you completed your licensing qualification with us, undertook professional development training, or have continued your career journey throughout the property services sector, it has been a privilege to have played a small part in your success.

🏡 While our time as an RTO has come to an end, our commitment to the real estate industry continues.

🎓 **Industry Training Consultants** will remain an approved Continuing Professional Development (CPD) provider across New South Wales, focusing on the delivery of high-quality non-accredited training and professional development programs for real estate professionals.

🛡️ At the same time, we are expanding our focus nationally through our sister company, **AgentSafe For Real Estate**, assisting agencies to navigate Australia's new AML/CTF obligations. Through consulting, compliance support, and compliance framework implementation, we will continue helping real estate professionals meet their regulatory obligations with confidence.

🤝 Thank you again for your support, trust, and loyalty over the past two decades. We look forward to continuing to work with the industry in this exciting new phase.

— **George Rousos**
Managing Director

✨ *The chapter is changing, but our commitment to the real estate industry remains stronger than ever.*

13/08/2026

Following our CPD class yesterday, one thing became very clear:

There is still a lot of confusion about what a compliant AML/CTF program actually looks like in a real estate business.

A generic template doesn't become compliant because it says “real estate”.

And a CRM integration or AML software feature doesn't, by itself, constitute an AML/CTF program.

Software can support compliance — but it cannot replace the framework.

Your AML/CTF program needs to reflect the nature, size and complexity of your business, identify the risks across your operations, and establish the policies, procedures, systems and controls needed to manage those risks.

That's the focus of this video.

If you're a real estate professional trying to work out what your business actually needs to have in place, I hope this helps cut through some of the confusion.

Don't buy the label. Look under the bonnet.

Bridging the Gap: Real Estate AML/CTF Compliance The real estate sector is facing an unprecedented culture shock as fede...
12/08/2026

Bridging the Gap: Real Estate AML/CTF Compliance

The real estate sector is facing an unprecedented culture shock as federal anti-money laundering and counter-terrorism financing obligations collide with a traditional sales-first mentality.

Following our CPD class today, the general feedback from students highlighted a massive structural disconnect on the ground:

"Lots of confusion, because AUSTRAC's language and resources doesn't really apply to the nature of real estate."

As one student noted after getting things cleared up:

"Many thanks George, the explanations and discussions made the whole thing much clearer. I will talk to my boss (when I can get her) about the fact that we need a program in place."

The Core Problem

When statutory guidance is written primarily through a banking and finance lens, it leaves property professionals stranded. Real estate isn't a digital bank account - it is a physical, fast-paced transaction environment involving unique asset conditions, decentralised parties, and on-the-ground operational risks.

Relying on generic tech-stack app "shortcuts" or superficial policy templates creates a false sense of security. As regulators have repeatedly stressed, a template or generic tool won't cut it if it doesn't reflect the true operational risks of the business.

It is time to move past treating compliance as a mere administrative speed bump and build frameworks tailored specifically to the realities of property.

The Fatal Flaw in Underquoting: How Federal AML Scrutiny Just Killed the GameFor years, some operators treated underquot...
03/08/2026

The Fatal Flaw in Underquoting: How Federal AML Scrutiny Just Killed the Game

For years, some operators treated underquoting as a routine marketing cost to juice buyer interest before quietly adjusting price expectations.

That game is over.

With NSW Fair Trading projecting a late 2026 commencement for new underquoting amendments, and the rollout of federal AML Tranche 2 reforms, playing fast and loose with pricing is no longer just a state conduct issue—it’s a major financial crime hazard. Federal AML scrutiny makes traditional underquoting practically impossible because every price adjustment, funding source, and valuation metric must lock together in an airtight audit trail.

What AUSTRAC Auditors Are Trained to Scrutinise: Federal regulators don't look at pricing through a standard consumer lens. AUSTRAC auditors are trained to hunt down unexplained price variances, sudden mid-campaign shifts, and gaps between initial marketing estimates and final transaction metrics. They treat these as frontline indicators of value-transfer schemes and illicit capital injection. Dropping a price guide without rigorous economic justification triggers immediate federal red flags.

The Strategic Solution: Shift the Onus to Vendors To protect agents from bearing the full evidentiary weight of market estimation, legislation should mandate that vendors provide an independent, certified pre-sale valuation prior to marketing.

Objective Baseline: Establishes an arms-length baseline price from day one.
Liability Protection: Removes guesswork and legal exposure from the agent.
Regulatory Anchor: Creates a tamper-proof anchor for both Fair Trading and federal AML audits.

Basic ID apps and static PDF onboarding forms won't save agencies here. Compliance isn't a 10-minute app setup; it requires enterprise-wide risk management linking market pricing, vendor data, and transaction monitoring.

How is your agency preparing for the collision between state pricing rules and federal AML audits?

AUSTRAC NSW Fair Trading

Enrolling with AUSTRAC isn't the finish line—it's the starting line.Now that the 29 July enrolment deadline has passed, ...
01/08/2026

Enrolling with AUSTRAC isn't the finish line—it's the starting line.

Now that the 29 July enrolment deadline has passed, the real challenge for the real estate industry is only just beginning.

From what I'm seeing, many agencies have:

*attempted to manage their obligations using Word documents and spreadsheets;
*purchased an AML/CTF manual but haven't implemented an ongoing compliance framework;
*invested in onboarding or identity verification solutions, believing that customer verification alone satisfies their AML/CTF obligations; or
*simply don't yet understand that enrolling with AUSTRAC is only the first step.

This week I had the opportunity to speak with AUSTRAC about these issues, including the concept of a property-centric AML/CTF compliance framework.

One thing became very clear: there is still significant confusion across the industry about what an effective AML/CTF program actually involves.

There is an important distinction between:
✔️ enrolling with AUSTRAC;
✔️ verifying a customer's identity; and
✔️ implementing and maintaining an effective AML/CTF program.

These are not the same thing.

An AML/CTF program extends well beyond onboarding. It requires governance, documented risk assessments, customer due diligence, ongoing monitoring, staff training, record keeping, independent evaluation and, importantly, the ability to demonstrate that the program is operating effectively over time.

With mandatory CPD training now underway, I expect awareness of these ongoing obligations to increase significantly. As the industry moves beyond enrolment, I believe the conversation will shift from "Have you enrolled?" to "Can you demonstrate that your AML/CTF program is effective?"

The agencies that recognise that distinction early will be far better prepared as AUSTRAC's compliance activities continue to mature.

Subject: The "Discretionary" Farce: Why Ex Gratia Schemes Are Just Avoidance in Disguise(Thanks Mulligan, Buyers Agents ...
24/07/2026

Subject: The "Discretionary" Farce: Why Ex Gratia Schemes Are Just Avoidance in Disguise

(Thanks Mulligan, Buyers Agents JP for sending us the Groves paper).

With the July 29 Treasury reconciliation deadline fast approaching, and ahead of the second and final explosive file landing on the desk of the Auditor General's Office, it’s worth examining a critical gap in our legal landscape highlighted in legal scholarship (such as Professor Matthew Groves' work on the Equality of Arms in Administrative Review).

https://law.unimelb.edu.au/__data/assets/pdf_file/0009/4808817/04-Groves-726.pdf

The entire architecture of NSW’s ex gratia (Act of Grace) framework rests on a convenient legal fiction. Bureaucrats love to hide behind the mantra that these payments are purely "discretionary" and that granting them has nothing to do with the government accepting legal liability.

Let’s call it what it is: a complete, utter farce.

In reality, these schemes are deployed precisely because the alternative—letting an aggrieved citizen or business test systemic regulatory incompetence through costly litigation—would expose the Crown to massive public liability, formal findings of maladministration, and eye-watering legal costs at the taxpayers' expense.

Why the "Discretionary" Label Falls Apart:

*The Avoidance Mechanism: Ex gratia schemes aren't acts of benevolent state mercy; they are administrative pressure-release valves. When an agency messes up so badly that a court or tribunal would tear their decision to shreds, a discretionary payout becomes the cheapest way to buy silence and sweep structural failures under the rug.

*The Inequality of Arms: As administrative law experts point out, ordinary citizens and small operators face an immense power imbalance when matching legal resources against the State. When the government's own administrative framework breaks down—such as failing to provide valid approval pathways while weaponising rigid guidelines—telling the victim they must beg for "grace" rather than claim rightful compensation mocks the rule of law.

*No Policy Structure Equals Arbitrary Shielding: When an assistance scheme lacks a transparent, objective policy structure, it functions merely as an arbitrary shield to protect departments from owning up to their errors.

If NSW Treasury attempts an eleventh-hour, low-ball offer before the deadline, it misses the entire point. You can't paper over structural, inoperable regulatory flaws with pocket-change discretionary handouts once the underlying deception has been fully exposed.

The ledger is being reconciled, and the findings will speak for themselves.

Headline: NSW Governance in Default: From Ministerial Negligence to Systemic Fiscal LiabilityThe "eviction notice" deliv...
16/07/2026

Headline: NSW Governance in Default: From Ministerial Negligence to Systemic Fiscal Liability

The "eviction notice" delivered to Fair Trading Minister Anoulack Chanthivong by the Real Estate Institute of New South Wales [REINSW] this week is more than a call for political accountability—it is a symptom of a systemic collapse in governance across New South Wales.

For those of us analysing the state's regulatory health, the Minister's refusal to engage is not simply a political failing; it is an administrative mechanism used to suppress critical evidence of maladministration, regulatory fraud, and unreconciled state debt.

My latest forensic assessment of departmental files—spanning the Department of Customer Service (which encompasses NSW Fair Trading) and the NSW Department of Communities and Justice (DCJ)—reveals a pattern of systemic breakdown that extends well beyond individual portfolios. We are documenting:

Engineering of Debt Evasion: Evidence of state agencies actively facilitating the avoidance of liquidated civil debts and restitution orders.

Administrative Fragmentation: The deliberate weaponisation of leadership gaps (for example, the Commissioner shuffle) to block procedural fairness and effectively "lobotomise" the state's financial records.

Fiscal Complicity: Treasury's formal refusal to engage with a verified state liability exceeding $1 million, instead choosing administrative deflection while the Auditor-General's Office is already actively reviewing evidence of these unreconciled debts.

We have moved beyond the point of mere allegations. We are now documenting a formal Statutory Default in which the Crown Solicitor's Office forensic review window has expired, ministerial oversight has been bypassed through "anonymous" suppression, and the state's financial integrity is being actively compromised to avoid accountability.

The "circle of silence" between the DCJ, Fair Trading, Treasury and investigative oversight bodies is now under audit. If the current Cabinet cannot manage the integrity of its own portfolios, it has no business overseeing the state's most important asset classes.

The question for the Premier is simple:

How long can you continue to back a Cabinet that creates fiscal liabilities while ignoring the fundamental duties of public office?

Kate Washington MP please explain to the public how a 'humanitarian' or 'supportive' gesture for a carer qualifies as 's...
15/07/2026

Kate Washington MP please explain to the public how a 'humanitarian' or 'supportive' gesture for a carer qualifies as 'special circumstances' under the ex gratia framework. There is no moral or legal obligation for such a payment, particularly when it contradicts explicit departmental legal advice.

An ex gratia or act of grace payment is an exercise of executive prerogative, intended solely for instances where a person has suffered financial loss or detriment directly caused by the actions of Government - detriment that cannot be remedied through standard legal proceedings. By your own standards, this payment fails the test of causality and necessity.

This discrepancy is highlighted by the continued suppression of our own applications. We have an ex gratia application lodged with Anoulack Chanthivong 's office dating back to July 2025 that, to this day, has not even been issued a reference number. Meanwhile, our application LGL24/13731—which involves verified systemic failure, non-disclosure of a predatory debtor, and direct financial harm—has been buried by DCJ Legal due to ongoing corruption and maladministration.

This is not merely a delay; it is a compounding administrative ledger. This has been allowed to escalate solely due to departmental negligence, forcing liabilities onto the public purse that should have been resolved long ago through proper adherence to the GSF Act.

It is only through relentless escalation that this matter has finally reached NSW Treasury NSW Government, Audit Office of New South Wales and the NSW Ombudsman. Furthermore, the Inspector of the ICAC is now reviewing the communication blockade orchestrated by DCJ Legal.

If this 'humanitarian' standard is now the policy for the Department, the public deserves to know why cases involving actual, documented government-induced detriment are being silenced rather than reconciled. It is time for NSW Treasury to step in and restore fiscal and legal integrity to this scheme.

🚨 The 2026–2027 CPD Year Is Here!This isn't just another CPD year.With Australia's new AML/CTF laws now in force, the ex...
12/07/2026

🚨 The 2026–2027 CPD Year Is Here!

This isn't just another CPD year.

With Australia's new AML/CTF laws now in force, the expectations placed on real estate professionals have changed dramatically.

✅ More comprehensive learning outcomes
✅ More practical, competency-based training
✅ A more rigorous assessment process

At Industry Training Consultants, we don't just help you complete your CPD—we help you understand how to apply it in your day-to-day agency practice.

Our workshops cover:

✔ The compulsory 2026–2027 CPD topics
✔ Practical AML/CTF compliance
✔ Real-world scenarios
✔ Interactive classroom learning
✔ Competency-based assessment

We also provide specialist AML/CTF consultancy services and the AgentSafe compliance platform to help agencies meet their ongoing compliance obligations.

📅 Our 2026–2027 workshops are now open for enrolment, but places are limited.

👉 View course dates and book your place today:
2026–2027 CPD Course Dates & Enrolment
https://www.itc.nsw.edu.au/course-dates

We look forward to supporting you throughout the new CPD year.

Address

2 Portside Crescent
Maryville, NSW
2293

Opening Hours

Monday 9am - 5pm
Tuesday 9am - 5pm
Wednesday 9am - 5pm
Thursday 9am - 5pm
Friday 9am - 5pm

Telephone

+61240010128

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