1 July 2026 Back to all posts
Real Estate & AML

Tranche 2 Is Now in Effect. Here Is What Real Estate Agencies Need to Do.

From 1 July 2026, real estate agencies and buyer's agents are reporting entities under Australia's AML/CTF regime for the first time. If you are buying, selling, or leasing property on behalf of clients, you are captured.

AUSTRAC enrolment deadline
29 July 2026
⚠ In effect now

AML/CTF obligations for real estate agencies, buyer's agents, and conveyancers commenced 1 July 2026. Enrolment with AUSTRAC must be completed by 29 July 2026. Operating a designated service without enrolment is a criminal offence under the AML/CTF Act.

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1 July 2026, AML/CTF Tranche 2
Today,
the rules
changed.
Real estate agencies
Law firms & conveyancers
Accountants & tax agents
Trust & company service providers
Dealers in precious metals & stones
AUSTRAC enrolment deadline
29 July 2026
LiteAML
02 / 02
Less than 4 weeks to go
8
questions
Five minutes. No sign-up required.
The hardest part isn't the rules. It's knowing where you actually stand right now, and what to prioritise before the deadline.

Our free readiness check tells you whether Tranche 2 applies to your business and where your biggest gaps are.
Take the readiness check
liteaml.com.au/readiness-check
LiteAML
Scope

Who Is Captured Under Tranche 2?

From 1 July 2026, real estate agencies and buyer's agents that assist clients in buying, selling, or leasing residential or commercial property are reporting entities under the AML/CTF Act. This applies regardless of the value of the transaction or whether you act for the vendor or the buyer.

The designation covers agencies and agents acting in connection with the sale, purchase, or transfer of real property, as well as buyer's agents retained to identify and acquire property on a client's behalf. If property transactions are part of your service offering, you are in scope.

Why real estate?

Real estate has historically been one of the highest-risk sectors for money laundering in Australia. AUSTRAC's own guidance identifies property transactions as a primary vehicle for the placement and layering of illicit funds, which is precisely why the sector has been brought into the AML/CTF regime under Tranche 2.

Obligations

Five Things Your Agency Must Have in Place

Here is what the regime requires of real estate agencies and buyer's agents from 1 July 2026. These are not optional steps: each is a legal obligation under the AML/CTF Act.

1
Enrol with AUSTRAC before 29 July 2026
Enrolment is the starting point and the most time-critical step. It is separate from having a compliance programme and must happen first. All agencies providing designated services on or after 1 July 2026 must enrol by 29 July. New agencies commencing after 1 July have 28 days from the date they first provide a designated service. Enrol via AUSTRAC Online.
Deadline: 29 July 2026
2
Develop a documented AML/CTF Program
Your agency must have a written AML/CTF program that sets out how you identify and manage the risk of money laundering through property transactions. The program must be tailored to your specific business: you cannot use a generic template or borrow one from an industry body. It must be approved by a responsible officer and kept up to date as your business and risk profile changes.
Required before providing designated services
3
Designate a compliance officer
Your agency must appoint an AML/CTF compliance officer who is responsible for the programme and accountable for the agency's obligations under the new regime. This person must have sufficient authority and resources to carry out the role effectively. For smaller agencies, this may be the principal or a senior employee with appropriate training.
Required
4
Implement customer due diligence (CDD) processes
You must verify the identity of vendors, buyers, landlords, and clients before commencing work on their behalf. This means collecting and verifying full legal name, date of birth, and address using acceptable identity documents or electronic verification. CDD must be completed before the designated service is provided, not at the point of settlement. See AUSTRAC's initial CDD guidance for accepted methods.
Required before providing designated services
5
Establish a transaction risk assessment process
Not all property transactions carry the same risk. Your AML/CTF program must include a process for identifying higher-risk transactions, including those with large cash components, third-party payments, clients whose source of funds is unclear, or structures that obscure beneficial ownership. Higher-risk transactions require enhanced due diligence before you proceed.
Required
Readiness

Not Sure Where Your Agency Stands?

Before the deadline, the most useful thing you can do is understand your current position clearly. Our free readiness check covers the five obligation areas above in eight short questions, takes about five minutes, and requires no sign-up.

8
questions
Five minutes. No sign-up required.
The hardest part is knowing where you actually stand right now, and what to prioritise before the deadline. Our free readiness check tells you whether Tranche 2 applies to your business and where your biggest gaps are.
Take the readiness check →

LiteAML helps real estate businesses get compliant.

From enrolment through to an ongoing AML/CTF program, without the complexity or cost of engaging a large advisory firm.

Get in touch →
Real Estate AML/CTF Tranche 2 AUSTRAC Customer Due Diligence Buyer's Agents Enrolment
This article is general information only and does not constitute legal or compliance advice. Consult a qualified AML/CTF professional for advice specific to your business.