AUSTRAC Tranche 2 real estate: the complete compliance guide for agencies — AML Simple

From 1 July 2026, every real estate agency in Australia that brokers property sales must comply with anti-money laundering and counter-terrorism financing laws. This is not optional, the deadline is firm, and AUSTRAC has said it will not be extended.

This guide covers everything your agency needs to know — the seven obligations, the key deadlines, the penalties for non-compliance, and the fastest way to get your program in place.

The fastest path to compliance

If you want to get your foundations in place today, three steps cover the essentials — around 22 minutes from start to finish:

Sign up to AML Simple — around 2 minutes. Enter your ABN and AML Simple pulls your registered business details from the ABR automatically. Your organisation profile is pre-filled.
Use the AUSTRAC Enrolment Cheat Sheet — around 5 minutes. Open AUSTRAC Connect in one tab, open the Cheat Sheet in another. Every field AUSTRAC needs is pre-filled from your account. Copy-paste down the form.
Run the AML/CTF Program Generator — around 15 minutes. The wizard asks about your agency's services, team size, and risk profile, then generates your AML/CTF program document — consistent with AUSTRAC's own Program Starter Kit structure.

You are enrolled, your program is built, and your compliance record-keeping has started. That is the hard part done.

Prefer to understand every obligation in depth first? Read on — the rest of this guide covers all seven of them.

Does Tranche 2 apply to your agency?

The obligations apply when you provide a designated service. For real estate, that means brokering the purchase, sale, or transfer of real estate for other people as part of a business.

This includes:

Selling or listing properties on behalf of vendors
Acting as a buyer's agent
Property auctioneers

Property management, leasing, and rental-only agencies are not regulated. If your agency only manages rentals and does no sales, you are outside the scope of Tranche 2.

Source: AUSTRAC summary of designated services for real estate

The seven core obligations

1. Enrol with AUSTRAC

Enrolment with AUSTRAC is open now. The deadline for real estate agencies is 29 July 2026.

You enrol via AUSTRAC Connect (austrac.gov.au). Once enrolled, you receive your AUSTRAC Account Number — which you will need for your Annual Compliance Report and other ongoing obligations.

Do this early. The earlier you enrol, the more time you have to build your program properly.

Source: AUSTRAC enrolment guidance

2. Build your AML/CTF program

Your AML/CTF program is the written document that explains how your agency identifies, assesses, and manages money laundering and terrorism financing risks. It is not a checklist you download once — it is a living document that reflects how your specific agency operates.

Your program must cover:

Your ML/TF/PF risk assessment (more on this below)
Your customer due diligence procedures — who you identify, what you collect, and how you verify
How you screen against sanctions lists
Who your Compliance Officer is
How you train your staff
How you keep records
How you file Suspicious Matter Reports and Threshold Transaction Reports

AUSTRAC publishes a free Program Starter Kit designed specifically for real estate agencies with 15 or fewer staff providing a single designated service. It includes Word templates you can customise.

AML Simple generates a program consistent with the Starter Kit structure — with your agency's details already built in from the questions you answered in the wizard.

For a deep dive into what your program must include, read What must your AML/CTF program actually include?.

3. Complete your ML/TF risk assessment

The risk assessment is the foundation of your AML/CTF program. It documents the money laundering and terrorism financing risks specific to your business — your customer types, the services you provide, how you deliver them, and where you operate.

AUSTRAC requires you to assess risk across four categories:

Customers — who you deal with and their risk profiles
Services — what designated services you provide
Delivery channels — how you deliver those services (in-person vs remote)
Geographic locations — where your agency operates and where transactions originate

You cannot risk-rate individual clients accurately until you have completed your entity-level risk assessment. It is not optional — it is the documented basis for everything else.

Source: AUSTRAC risk assessment guidance; AML/CTF Act 2006, s 165

For step-by-step guidance, read How to complete your ML/TF risk assessment as a real estate agency.

4. Appoint a Compliance Officer

Your AML/CTF program must appoint a Compliance Officer at senior management level. In a small agency, this is typically the principal.

The Compliance Officer is responsible for:

Implementing and managing the AML/CTF program day to day
Overseeing CDD processes and record-keeping
Ensuring SMRs and TTRs are filed when required
Conducting the Annual Compliance Report each year
Notifying AUSTRAC of any business changes within 14 days

You must notify AUSTRAC of your Compliance Officer's details by 29 July 2026. This is a legal requirement separate from enrolment.

Source: AUSTRAC obligations for newly regulated entities

5. Train your staff

Every staff member who performs AML-relevant duties must complete AML/CTF risk awareness training before they start those duties. You cannot wait until after 1 July 2026 to train staff who are already doing CDD work.

Training must cover:

What the AML/CTF Act requires
How to identify suspicious activity
How to escalate concerns internally
How to perform CDD correctly
Record-keeping requirements

Training records must be retained for 7 years.

Source: AML/CTF Act 2006, s 26F(4)(e); AUSTRAC Program Starter Kit guidance on training

For a full breakdown of what training must cover, read AML/CTF staff training requirements for real estate agencies.

6. Conduct customer due diligence (CDD)

From 1 July 2026, your agency must complete customer due diligence on every client involved in a designated service transaction — buyers, vendors, and anyone acting on their behalf — before you provide the service.

Initial CDD requires collecting and verifying:

Full legal name
Date of birth
Residential address
Whether they are acting for another party (and if so, that party's details too)

Verification must use reliable and independent means — inspecting original documents in person, conducting a live video call with document comparison, or using an electronic verification service such as the Document Verification Service (DVS).

Ongoing CDD continues throughout your business relationship — you must keep client information current and re-screen against sanctions lists when those lists are updated.

Where a client is a company or trust, you must also identify the beneficial owners — individuals with 25% or more ownership, or effective control.

For a plain-English guide to CDD requirements, see Customer due diligence for real estate: a plain-English guide.

For beneficial ownership specifically, read Beneficial ownership in real estate: what AML/CTF rules require.

Source: AML/CTF Act 2006, s 34; AUSTRAC initial CDD guidance

7. Monitor transactions and file reports

Your program must include systems for detecting and reporting suspicious activity.

Suspicious Matter Reports (SMRs) must be filed when you have reasonable grounds to suspect money laundering, terrorism financing, or other criminal activity. Filing deadlines are strict:

Terrorism financing: within 24 hours
Money laundering or other: within 3 business days

Real estate-specific red flags include:

Cash structured below the $10,000 threshold then transferred to trust accounts
Purchases funded from multiple unrelated accounts or offshore entities
Property purchased sight-unseen at above-market price
Reluctance or refusal to provide identification documents

Threshold Transaction Reports (TTRs) must be filed within 10 business days when a transaction involves physical cash of $10,000 or more.

For a step-by-step guide to filing SMRs, read Suspicious matter reports for real estate agents: when and how to file.

Source: AML/CTF Act 2006; AUSTRAC guidance on SMRs

Key deadlines

Date	What you need to do
Now	Start your AML/CTF program; begin staff training
31 March 2026	AUSTRAC enrolment opens
1 July 2026	All obligations commence — CDD, screening, record-keeping starts
29 July 2026	Enrolment deadline; Compliance Officer notification deadline
31 March 2027	First Annual Compliance Report due (covering 1 July–31 December 2026)

Source: AUSTRAC key dates

For a week-by-week action plan, read Your AML compliance timeline: what real estate agencies need to do before July 2026.

What happens if you miss the deadline?

Penalties under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 are serious:

Up to $33 million per contravention for a body corporate
Up to $6.6 million per contravention for an individual

Penalties stack. Failing to enrol, having no AML/CTF program, and missing CDD obligations are three separate potential contraventions.

AUSTRAC has been clear: the deadline will not be extended. The July 2026 FATF mutual evaluation of Australia makes any softening of enforcement posture unlikely.

For a detailed breakdown of enforcement risk, read AUSTRAC Tranche 2 penalties: what real estate agencies face.

Source: AML/CTF Act 2006; AUSTRAC compliance and enforcement

What "good compliance" looks like in practice

An agency that is compliant by 1 July 2026 has:

Enrolled with AUSTRAC and received its AUSTRAC Account Number
A documented AML/CTF program, approved by senior management
A named Compliance Officer notified to AUSTRAC
Staff trained before performing any AML-relevant duties
CDD processes in place — ready to collect and verify client identity on the first transaction from 1 July
Sanctions screening set up and running
A system for identifying, recording, and filing SMRs and TTRs
Record-keeping in place to retain all AML records for a minimum of 7 years

That is the practical checklist. Every item on it is achievable before the deadline.

Frequently asked questions

Does this apply to commercial real estate agents? Yes. The designated service is brokering the purchase, sale, or transfer of real estate broadly — it is not limited to residential property. Commercial agents who facilitate sales transactions are regulated.

What if I only do property management? Property management, leasing, and rental management are not designated services under Tranche 2. If your agency does only that and no sales, you are outside scope.

Does each office in a franchise need its own program? Typically yes. Each entity that is a reporting entity must maintain its own AML/CTF program. Franchise head offices may provide a program template, but each franchisee office is responsible for its own compliance — including its own enrolment, Compliance Officer appointment, and CDD records.

When do I need to start doing CDD? From 1 July 2026, CDD is required on all clients before you provide a designated service. You should have your procedures in place before that date so your team is ready on day one.

This content is general information only and does not constitute legal or AML/CTF advice. For tailored advice, consult a licensed AML/CTF advisor. AML Simple is a compliance tool, not a law firm.

Want a personalised Tranche 2 readiness score for your agency? Take the free 5-minute Readiness Check → amlsimple.com/check