Real estate agents in Australia are facing their most significant compliance overhaul in decades. The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 extends Australia’s AML/CTF regime to a new cohort of “Tranche 2” entities — and real estate agents are among the first in scope. With the 1 July 2026 deadline approaching, understanding what AUSTRAC Tranche 2 real estate agents obligations actually require is essential for anyone operating in residential or commercial property transactions.
\nProperty has long been recognised as a preferred vehicle for laundering illicit funds. The Financial Action Task Force (FATF) has consistently flagged real estate as a high-risk sector, noting in its guidance on money laundering through the real estate sector that property transactions allow criminals to layer and integrate large sums with relative ease. In Australia, the Australian Criminal Intelligence Commission’s 2023 Organised Crime in Australia report identified real estate as a key conduit for proceeds of crime, including funds linked to drug trafficking and foreign corruption.
\nUntil the Tranche 2 reforms, Australia was one of the few FATF member jurisdictions that had not brought real estate agents under a formal AML/CTF regime. That gap is now being closed.
\nUnder the amended Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act), real estate agents who provide a “designated service” — broadly, facilitating the buying or selling of real property — will be required to:
\nThe primary compliance date for most Tranche 2 entities — including real estate agents — is 1 July 2026. AUSTRAC has indicated it will take a risk-based, educative approach to compliance in the early transition period, but this does not mean obligations are optional. The expectation is that entities will have their AML/CTF programmes documented and their CDD procedures operational by the commencement date.
\nSome obligations may be subject to phased implementation; agents should monitor AUSTRAC’s website and guidance materials closely, as transitional rules for specific requirements (such as transaction monitoring) may vary.
\nWith fewer than two months to the July 2026 deadline, agents should prioritise the following:
\nConduct a risk assessment. Evaluate the types of transactions you facilitate, the geographies involved, the customer profiles you typically deal with, and any third-party relationships. This assessment underpins your AML/CTF programme.
\nDraft your AML/CTF programme. If you don’t have one, you need one. AUSTRAC has published templates and guidance for small businesses entering the regime for the first time.
\nSelect a CDD and screening solution. Manual identity verification and name-screening processes are inadequate at scale. Purpose-built tools allow agents to screen individuals and entities against global sanctions lists, PEP databases, and adverse media sources in real time.
\nTrain your staff. The AML/CTF Act requires that relevant employees receive AML/CTF training appropriate to their role.
\nEnrol with AUSTRAC. This must happen before you provide a designated service after the commencement date.
\nNameScan provides a pay-as-you-go AML screening platform that allows real estate agents to run identity verification, PEP checks, sanctions screening, and adverse media searches without a subscription commitment. This is particularly well-suited to smaller agencies managing variable transaction volumes. Each check is run on demand, with results delivered in real time and stored for audit purposes — meeting the record-keeping requirements under the AML/CTF Act.
\nTranche 2 refers to the second wave of entities brought under Australia’s Anti-Money Laundering and Counter-Terrorism Financing Act 2006. Real estate agents who facilitate property transactions are included and must comply from 1 July 2026.
\nAgents must enrol before providing a designated service after the commencement date of 1 July 2026, or within 28 days of first providing such a service if they commence after that date.
\nAt minimum, a Part A covering risk assessment and governance, and a Part B covering customer due diligence procedures, screening, staff training, and record keeping. AUSTRAC provides guidance and templates for small businesses.
\nYes. CDD requirements under the AML/CTF Act include identifying whether customers are PEPs or subject to sanctions, and conducting enhanced due diligence where appropriate.
\nNon-compliance with the AML/CTF Act can result in civil penalties, infringement notices, and — in serious cases — criminal prosecution. AUSTRAC has broad enforcement powers including enforceable undertakings and licence suspension.
\nAustralia’s real estate sector is entering a new compliance era. Agents who prepare early — building their AML/CTF programme, implementing robust customer due diligence, and enrolling with AUSTRAC before the July deadline — will be far better positioned than those who wait. The cost of compliance is manageable; the cost of non-compliance is not.
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