For Real Estate Agents

AML/CTF program for real estate agents — AUSTRAC Tranche 2 from July 2026

Property is the single largest channel for laundered funds in Australia. From 1 July 2026 every real-estate agency that buys, sells or leases property on behalf of a client is a reporting entity under the AML/CTF Act.

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Compliance Challenges for Real Estate Agents

AUSTRAC's 2024 National Risk Assessment rates real estate as a HIGH money-laundering risk. From 1 July 2026 your agency needs an AML/CTF program. AutoAML drafts it in minutes.

AUSTRAC has formally rated your sector 'high risk'

The 2024 Money Laundering National Risk Assessment ranks real estate as one of the highest-risk sectors in the country. Expect AUSTRAC supervision to be active from day one of Tranche 2, not eventual.

Third-party payments are a common typology you'll need to spot

Funds wired from an unrelated company or overseas account, last-minute changes to settlement instructions, and 'gifts' from unverified sources are all known red flags AUSTRAC expects you to monitor and report.

Trust and corporate purchasers obscure beneficial ownership

When a buyer is a discretionary trust or shelf company, the 25 % beneficial-owner identification rule under Chapter 4 of the AML/CTF Rules applies. Your CDD has to look through structures, not stop at the contract name.

Property managers handle ongoing client money

Trust-account inflows from tenants, owners overseas, and bond transfers all create transaction-monitoring obligations. Property management is rarely exempt just because it's recurring.

What Real Estate Agents Need for Compliance

The AML/CTF Act 2006 (Cth) and the AML/CTF Rules require all reporting entities to maintain these documents and procedures.

Agency-wide AML/CTF Program covering Part A and Part B — s 81 of the Act

ML/TF Risk Assessment specific to sales, leasing and property management

Customer Due Diligence procedures for buyers, sellers and beneficial owners

PEP and sanctions screening before settlement

Suspicious Matter Report (SMR) workflow integrated with sales staff

Threshold Transaction Report (TTR) procedure for $10,000+ cash deposits

Trust-account and settlement transaction-monitoring rules

Record-keeping for 7 years post-transaction (s 107)

Deadline & Applicability

Real estate agents, property managers and agencies acting in property transactions become reporting entities on 1 July 2026 under the AML/CTF Amendment Act 2024. AUSTRAC has signalled guided enrolment from late 2025 and active supervision from commencement.

Last reviewed: 18 April 2026 · Information is general guidance, not legal advice.

How AutoAML Helps Real Estate Agents

AI-Generated Documents

All 13 compliance documents drafted from your service mix and risk profile — Part A, Part B, risk assessment, CDD scripts, the lot.

Team & Audit Trail

Invite your team, assign Compliance Officer roles, and keep a tamper-evident audit log AUSTRAC supervisors can read.

SMR & TTR Built-in

Reporting workflows, training tracking, annual review reminders and document version control — so the program stays alive after day one.

Frequently Asked Questions

Real Estate Agents & AUSTRAC: common questions

Do residential-only agencies need an AML/CTF program?

Yes. The designated service is acting for a client in the buying, selling or leasing of real property. There is no carve-out for residential-only work — apartments, houses and off-the-plan all count.

Does my property-management business need a separate program?

If property management is run through the same legal entity as sales, one program covering both lines is fine. If they're separate entities, each entity that provides a designated service needs its own enrolment and program.

Who counts as the beneficial owner of a trust buyer?

Under Chapter 4 of the AML/CTF Rules, you need to identify any individual who ultimately owns or controls 25 % or more, plus the settlor of the trust. For corporate trustees, you look through to the controllers of the company.

What if a buyer wants to pay a deposit in cash?

Any cash or cash-equivalent transaction of $10,000 or more triggers a Threshold Transaction Report (TTR) under s 43, lodged with AUSTRAC within 10 business days. Multiple smaller cash payments that look like structuring should be reported as an SMR.

We use a conveyancer or settlement agent — does that cover us?

No. From 1 July 2026 the agency is a separate reporting entity from the conveyancer. Both have their own CDD and reporting obligations. You can share information but not delegate liability.

How does this interact with the Foreign Investment Review Board (FIRB)?

FIRB approval is a separate regime from AML/CTF. A FIRB-approved purchase still needs full CDD on the buyer, and the funding source — particularly remittances from high-risk jurisdictions — is the area AUSTRAC will probe in supervisory visits.

Related industries under AUSTRAC Tranche 2

Many firms work across more than one designated-service category. Check the related sectors below.

For Conveyancers

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All 13 AUSTRAC-aligned documents drafted from your service mix. Free until the 1 July 2026 deadline.

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