The new AML rules are live — what real estate agents can learn from sectors already on them
The updated AML/CTF framework commenced 31 March 2026. Banks and casinos are already operating under it. Real estate agents are next — 1 July 2026. Here is what you can learn from sectors that got there first.
The new AML rules are live — what real estate agents can learn from sectors already on them
As of 31 March 2026, Australia's updated Anti-Money Laundering and Counter-Terrorism Financing framework is in effect.
Banks, casinos, gambling venues, and other existing reporting entities are now operating under the revised rules. For the sectors that have been in the regime for years, 31 March was an upgrade. For real estate agents, it is a signal: the clock is running.
Your deadline is 1 July 2026 -- 91 days from today.
What changed on 1 April?
The AML/CTF Amendment Act 2024 extended the regime to Tranche 2 sectors (including real estate) but also modernised the rules for everyone already in it. From 1 April 2026:
- The old Part A / Part B program structure is gone. Programs are now outcomes-based and risk-driven -- organised however the entity needs, provided they meet the substance requirements.
- Proliferation financing (PF) joins money laundering and terrorism financing as a mandatory risk category in every program. Existing reporting entities must update their risk assessments to cover PF explicitly.
- Enhanced obligations apply for foreign politically exposed persons (PEPs) and high-risk customers.
- Independent evaluation requirements are now standardised -- every three years at minimum.
For banks and casinos, this means updating programs they have had for years. For real estate agents, it means building a program that already incorporates these requirements from day one.
That is actually an advantage.
What do existing sectors actually do?
Walk into any Australian bank branch and ask for a mortgage application. Before the loan proceeds, the bank will verify your identity using an electronic verification service -- confirming your name, date of birth, and address against government records. If you are a company, they will want to know who the beneficial owners are (anyone with 25% or more ownership or effective control). If anything looks unusual, the file gets escalated.
This is not bureaucracy. It is a documented process -- written into the bank's AML/CTF program, tested during audits, and updated when regulations change.
Casinos do the same. Before you sit down at a high-value table, your identity may be verified. Large cash transactions are reported to AUSTRAC. Staff are trained on what suspicious activity looks like and how to escalate without alerting the customer (the "tipping-off" prohibition is real -- it carries criminal penalties).
The sectors that have been in the regime for years do not treat compliance as an annual checkbox. They run it as a continuous workflow embedded into their operations.
What real estate agents face from 1 July
The obligations are the same in structure. Different in context.
From 1 July 2026, before your agency brokers a purchase or sale, you must:
- Verify the identity of every buyer and seller you act for (individuals and companies)
- Screen every client against the DFAT consolidated list (sanctions) and PEP lists
- Identify beneficial owners for any company or trust client
- Apply enhanced checks when anything triggers concern -- unexplained urgency, cash payment requests, offshore fund sources
And ongoing from there:
- Lodge suspicious matter reports (SMRs) with AUSTRAC within 3 business days of forming a suspicion (24 hours for terrorism-related matters)
- Report any cash transactions of A$10,000 or more (threshold transaction reports)
- Keep all records for 7 years
- Review and update your program regularly
- Train your staff annually
The difference between you and the bank is experience. They have had years to embed these workflows into their operations. You have 91 days to build them from scratch.
One thing experienced sectors do that agencies should start now
The single most useful thing you can do this week is appoint your compliance officer.
In regulated sectors, the compliance officer role is not an afterthought. It is the person who owns the program, reviews suspicious activity, signs off on SMR lodgements, and keeps training records. For a small agency, it is usually the principal.
You do not need special qualifications to be a compliance officer. AUSTRAC requires you to appoint someone at senior management level -- someone with authority to act when something looks wrong.
Appointing that person now gives you a name to put on your AUSTRAC enrolment (which opened 31 March and is required by 29 July). It also signals to your team that compliance is owned, not optional.
Where to go from here
AUSTRAC published a free Program Starter Kit specifically for real estate agencies with up to 15 staff providing one designated service. It is three Word documents covering your risk assessment, CDD procedures, and monitoring obligations. You complete them, customise them to reflect your business, and get them approved at principal level. That set of documents is your AML/CTF program.
If you would prefer a guided workflow that asks you the same questions and generates a program document for you -- without starting from a blank template -- AML Simple's program wizard covers the same sections. Your answers build your program.
Either way, start now. 91 days is enough time to get this right if you start this week. It is not enough time if you leave it to June.
Source: Anti-Money Laundering and Counter-Terrorism Financing Act 2006; AML/CTF Amendment Act 2024. This post describes general AML/CTF obligations and does not constitute legal or compliance advice.