From 1 July 2026, Australia’s Anti‑Money Laundering and Counter‑Terrorism Financing (AML/CTF) laws will apply to real estate agents and agencies for the first time.
These long‑anticipated reforms, commonly referred to as “Tranche 2”, will bring real estate businesses, alongside conveyancers, lawyers and accountants, into the same regulatory framework that already applies to banks. The intent is clear: to prevent property transactions being used to launder money or finance criminal activity.
For real estate agencies, this represents a major regulatory change that will impact onboarding, sales processes, record‑keeping, and staff training.
This article provides an overview of what’s changing, who is affected, and what your agency should be doing now to prepare.
What Is Changing Under the AML/CTF Laws in Australia?
From 1 July 2026, real estate agencies will become “reporting entities” under the AML/CTF Act.
This means agencies will have new legal obligations to:
- Identify and verify clients (Customer Due Diligence / CDD)
- Assess money‑laundering and terrorism‑financing risk
- Monitor transactions for suspicious activity
- Report certain matters to AUSTRAC
- Maintain detailed compliance records
- Train staff on AML/CTF obligations
These requirements are designed to ensure greater transparency in property transactions and reduce the risk of criminal misuse of real estate.
Who Do the AML/CTF Reforms Apply To?
The reforms apply to businesses involved in the sale or transfer of real property, including:
- Residential real estate agents
- Commercial real estate agents
- Property developers selling directly to buyers
- Conveyancers
The reforms do not apply to property management and leasing (unless the lease term exceeds 30 years).
Key AML/CTF Obligations for Real Estate Agencies in Australia
AUSTRAC Enrollment
All affected agencies must enrol with AUSTRAC.
Registration is now open and this must be completed by 29 July.
AML/CTF Program
Every agency must maintain a written AML/CTF Program that is proportionate to the size, nature, and risk of the business.
This includes:
- A documented risk assessment
- Internal AML/CTF policies and procedures
- Governance and oversight arrangements
AUSTRAC has confirmed that starter kits will be available for agencies with fewer than 15 staff, making compliance more manageable for smaller businesses.
Customer Due Diligence (CDD)
Agencies will be required to verify the identity of both buyers and sellers.
Seller’s agents must:
- Complete CDD on the Vendor when the Sales Agency Agreement is signed
- Complete CDD on the Purchaser once an offer is accepted and a contract is, or is about to be, signed
Buyer’s agents must:
- Complete CDD on the Purchaser when an agreement to find or identify a property is signed
- Complete CDD on the Vendor when the transaction is expected to proceed
Identity verification will become a standard part of sales workflows.
Enhanced Due Diligence (EDD)
Additional checks apply where there is a higher risk of money laundering, including transactions involving:
- Foreign buyers
- Trusts or complex ownership structures
- Politically Exposed Persons (PEPs)
These matters will require deeper scrutiny and enhanced record‑keeping.
Suspicious Matter Reporting
If suspicious behaviour or activity is identified, agencies must submit a Suspicious Matter Report (SMR) to AUSTRAC within three business days of forming that suspicion.
Agencies must also report:
- Cash transactions over $10,000
- Requests involving international fund transfers
Training and Record Keeping
All staff with AML-related duties must receive AML/CTF training, and compliance records must be retained for at least seven years.
What The AML/CTF Legislation Means for Small to Mid‑Sized Agencies
For many agencies, these reforms will require significant operational changes.
Expect adjustments to:
- Client onboarding
- Listing and sales processes
- Documentation and record‑keeping
- Staff responsibilities and training
Many agencies will choose to adopt digital AML or Know‑Your‑Client (KYC) solutions to streamline identity verification and compliance.
Failure to comply can lead to civil penalty orders and enforcement action by AUSTRAC, making early preparation essential.
AML/CTF Preparation Checklist for Real Estate Agencies
Between now and 1 July 2026, agencies should:
- Confirm whether your business provides designated real estate services
- Enrol with AUSTRAC
- Appoint an AML/CTF compliance lead
- Ensure directors, owners, and staff understand the new obligations
- Map current sales and onboarding processes to identify CDD touchpoints
- Evaluate and implement an AML/KYC solution if required
- Prepare an AML/CTF risk assessment and policy
- Develop and maintain a tailored AML/CTF Program
- Schedule AML/CTF training for all relevant staff
- Test systems and processes before go‑live to minimise disruption
How Eckermanns Can Help
The Tranche 2 AML/CTF reforms represent one of the most significant regulatory shifts the real estate industry has faced in years, and Eckermanns will assist real estate agencies through every stage of this change.
Our in‑house Compliance Officer, Sam Michael, is available to answer agents’ questions and provide clear, practical guidance on how the legislation will apply to day‑to‑day agency operations.
To make compliance as easy and efficient as possible, our sister business and real estate compliance technology platform, Greatforms has integrated with three outsourced AML providers, allowing agencies to embed AML and KYC checks directly into their existing workflows. This integration will significantly reduce administrative burden and enhance compliance.
If you would like guidance on how these changes affect your agency or assistance preparing for compliance ahead of 1 July 2026, contact Sam Michael on 8235 3936 or email sam.michael@eckermanns.com.au
