AML/CTF Compliance for Real Estate Agents in Australia 2026: What You Need to Do Right Now

From 1 July 2026, real estate agents will be reporting entities under Australia's Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (the AML/CTF Act). If your agency buys, sells or transfers real estate for clients, your agency will sit inside the same regime that has applied to banks and casinos for the better part of two decades — and AUSTRAC, Australia's financial intelligence regulator, expects you to be ready well before then.

This is the plain-English version of what real estate AML compliance in Australia actually requires. It is a starting-point checklist, not a substitute for advice on your specific business.

Why real estate is now regulated

These changes come from the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024, which received Royal Assent in December 2024 and extends the AML/CTF regime to "Tranche 2" entities: real estate professionals, lawyers, conveyancers, accountants, dealers in precious metals and stones, and trust and company service providers.

Property has long been flagged — by AUSTRAC and by the global Financial Action Task Force (FATF) — as an attractive channel for laundering illicit funds. High transaction values, complex ownership structures and the involvement of overseas buyers make real estate a recognised money-laundering vulnerability. Tranche 2 is Australia's response.

Are you actually in scope?

AUSTRAC's guiding principle is simple: you are a reporting entity because you provide a designated service, not because of the label on your business card. For real estate, the designated services centre on acting in connection with the sale, purchase or transfer of real estate — generally regardless of the property's value, and regardless of whether you act for the buyer or the seller. Buyer's agents and property developers selling their own stock can also be captured.

A practical point worth confirming for your own service mix: routine property management and residential leasing are generally not designated services. The obligations attach to the transactional side of the business — brokering the deal — rather than collecting rent. Because the obligation follows the service, agencies that do both should map which parts of their business are in scope.

The compliance checklist

Here is what an in-scope agency needs to have in place. Treat each item as an ongoing discipline, not a one-off task.

1. Enrol with AUSTRAC

Enrolment places you on AUSTRAC's Reporting Entity Roll. Enrolment opened on 31 March 2026, obligations commence on 1 July 2026, and the enrolment deadline for new Tranche 2 entities is 29 July 2026. Under the Act you must be enrolled before you provide a designated service after commencement. Enrolment is free and done through AUSTRAC Online. Providing a designated service without being enrolled is itself a breach.

2. Conduct an ML/TF risk assessment (your business-wide risk assessment)

Before you write a single policy, you assess risk. Every reporting entity must conduct a money laundering, terrorism financing and proliferation financing (ML/TF) risk assessment appropriate to the nature, size and complexity of its business. This is the document many agencies call the "business-wide risk assessment" (BWRA), and it is the foundation everything else is built on. It must have regard to your customers, the services you provide, your delivery channels, the foreign jurisdictions you deal with, and AUSTRAC's published risk assessments. See our BWRA guide for real estate agencies for a step-by-step breakdown.

3. Build your AML/CTF policies

The 2024 reforms removed the old prescriptive "Part A / Part B" program split. Your AML/CTF program now consists of two things: your ML/TF risk assessment and your AML/CTF policies — the procedures, systems and controls that manage the risks you identified. Your policies must be proportionate, approved by senior management, and actually implemented. AUSTRAC has been explicit that it expects tailored programs, not templates adopted without thought.

4. Appoint an AML/CTF compliance officer

You must appoint an AML/CTF compliance officer with appropriate seniority and authority to oversee the program day to day. In a small agency this is often the principal or a senior manager.

5. Carry out customer due diligence (CDD)

You must identify and verify your customers — buyers and sellers — and identify beneficial owners (the real people behind a company or trust). The reforms move to risk-based CDD: low-risk clients get a lighter process, while higher-risk situations (such as politically exposed persons, certain overseas buyers, or unusual cash arrangements) trigger enhanced due diligence. See our practical CDD guide for agents for a full walkthrough.

6. Train your staff

Everyone who provides designated services needs to understand the red flags, your CDD process, and the reporting obligations. Training is part of your program, not optional.

7. Report suspicious matters

If you suspect on reasonable grounds that a transaction or customer relates to money laundering, terrorism financing or another serious offence, you must lodge a Suspicious Matter Report (SMR) with AUSTRAC — within 3 business days (or 24 hours for terrorism financing). You must not "tip off" the customer. See our SMR guide for real estate agents for the trigger, the clock and the tipping-off prohibition.

8. Keep records and report annually

Reporting entities keep AML/CTF records (generally for seven years) and submit annual compliance reporting to AUSTRAC. Your program must also be independently evaluated at least every three years.

What AUSTRAC actually expects

AUSTRAC has signalled a risk-based, educative approach in the early transition period — but that is not the same as obligations being optional. The expectation is that in-scope agencies are enrolled, have a documented risk assessment and AML/CTF policies, have appointed a compliance officer, have trained staff, and can lodge an SMR from day one.

Where Veriqua fits

Veriqua is a compliance platform designed to assist Tranche 2 real estate agencies. It is designed to assist with generating your ML/TF risk assessment, running and recording customer due diligence, managing SMR lodgement packs, tracking staff training and timestamping each obligation as you complete it — giving you an evidence trail you can show to a reviewer. Veriqua supports your obligations; it does not remove your responsibility as a reporting entity to comply with the law.

With the clock running toward 1 July 2026, the priority order above is the fastest path to a defensible position — and the earlier you start, the less you'll be competing for the same advisers and onboarding capacity as every other agency closer to the deadline.