What real estate agents must do under AUSTRAC Tranche 2 — AML Simple

Real estate agencies in Australia that broker property sales become regulated entities under Australia's anti-money laundering and counter-terrorism financing laws from 1 July 2026. That means seven new ongoing obligations — plus several things you need to have in place before that date.

This post breaks down each one in plain English.

Start here: the fastest path to getting compliant

Three steps cover your compliance foundations — around 22 minutes in total:

Sign up to AML Simple — around 2 minutes. Enter your ABN and AML Simple pulls your registered business details automatically. Your 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.
Run the AML/CTF Program Generator — around 15 minutes. The wizard asks the right questions about your agency and generates your AML/CTF program document, consistent with AUSTRAC's Program Starter Kit structure.

Enrolled, program built, record-keeping started. That is your compliance foundation in place.

Prefer to understand what each obligation actually requires before you start? Here is the full picture.

Does Tranche 2 apply to your agency?

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

That covers:

Sales agents listing and selling on behalf of vendors
Buyer's agents acting for purchasers
Auctioneers conducting property sales

Not covered: Property management, leasing, and rental management are not designated services. Agencies that only manage rentals and do no sales are not regulated.

Source: AUSTRAC real estate sector guidance

The seven obligations

Obligation 1: Enrol with AUSTRAC

You must enrol with AUSTRAC via AUSTRAC Connect. Enrolment opened 31 March 2026. The deadline for newly regulated entities is 29 July 2026.

Completing enrolment gives you your AUSTRAC Account Number, which you need for ongoing reporting obligations including your Annual Compliance Report.

Do it early — it typically takes less than 30 minutes once you have your agency details ready.

Obligation 2: Build an AML/CTF program

Your AML/CTF program is the written document describing how your agency identifies, assesses, and manages money laundering and terrorism financing risks. Every regulated entity must have one.

The program must cover your risk assessment, CDD procedures, sanctions screening approach, Compliance Officer, staff training, record-keeping, and how you detect and report suspicious activity.

AUSTRAC publishes a free Program Starter Kit with Word templates for agencies with 15 or fewer staff. AML Simple generates a program consistent with that structure in around 15 minutes.

The program is not a one-off task — you must keep it current as your business and the regulatory environment evolve.

Source: AML/CTF Act 2006, s 81; AUSTRAC program guidance

Obligation 3: Appoint a Compliance Officer

Your AML/CTF program must name a Compliance Officer at senior management level. In a small agency, this is typically the principal. In a larger agency, it might be the operations manager.

The Compliance Officer is responsible for implementing the program, keeping it current, overseeing CDD, ensuring SMRs and TTRs are filed on time, and conducting the Annual Compliance Report each year.

You must notify AUSTRAC of your Compliance Officer's details by 29 July 2026. Any subsequent change must be notified within 14 days.

Source: AUSTRAC summary of obligations for new regulated entities

Obligation 4: Conduct customer due diligence (CDD)

From 1 July 2026, you must identify and verify the identity of every client involved in a sales transaction — vendors, buyers, and anyone acting on their behalf — before you provide your service.

For individuals you must collect:

Full legal name
Date of birth
Residential address
Whether they are acting for another party

Identity must be verified using reliable and independent means: inspecting original documents in person, conducting a live video call with document comparison, or using an electronic verification service.

For companies and trusts, you must also identify the beneficial owners — the individuals who ultimately own or control the entity.

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

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

Obligation 5: Screen against sanctions lists

You must screen all clients against the DFAT Consolidated Sanctions List — the list of individuals and entities subject to Australian sanctions — at onboarding and on an ongoing basis as the list is updated.

The DFAT list is available at dfat.gov.au and is updated as changes occur. You should check it daily or use an automated screening tool.

You must also screen for Politically Exposed Persons (PEPs) — senior foreign political figures and their close associates. Foreign PEPs require Enhanced CDD: additional verification, source of funds confirmation, and senior management approval before proceeding.

AML Simple screens every client against the DFAT list automatically during CDD and re-screens when the list is updated.

Source: AML/CTF Act 2006; DFAT Consolidated List

Obligation 6: Train your staff

Every staff member who performs AML-relevant duties must receive AML/CTF risk awareness training before performing those duties. You cannot start doing CDD on 1 July 2026 with staff who have received no training.

Training must cover: the obligations, how to identify suspicious activity, how to escalate concerns, CDD procedures, record-keeping, and the consequences of non-compliance.

Training must be ongoing — at minimum annually. Training records must be retained for 7 years.

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

Obligation 7: Keep records for 7 years

All AML/CTF records must be retained for a minimum of 7 years. This includes:

Client identification and verification records
CDD records for each client
Sanctions screening results
Any SMRs or TTRs filed
Your AML/CTF program (all versions)
Staff training records
Risk assessment documents

Records must be accessible and retrievable — able to be provided to AUSTRAC on request.

Source: AML/CTF Act 2006, s 107

And two ongoing reporting obligations

Suspicious Matter Reports (SMRs): If you suspect a transaction may be related to money laundering, terrorism financing, or another serious crime, you must file an SMR. The deadline is 24 hours for terrorism financing suspicions, and 3 business days for money laundering or other suspicions.

Threshold Transaction Reports (TTRs): If a transaction involves physical cash of $10,000 or more, you must file a TTR within 10 business days.

Annual Compliance Report: From 2027, you must file an Annual Compliance Report covering each calendar year (1 January – 31 December), due by 31 March the following year. The first report covers 1 July – 31 December 2026 and is due 31 March 2027.

The obligations in summary

Obligation	When
Enrol with AUSTRAC	By 29 July 2026
Build your AML/CTF program	Before 1 July 2026
Appoint and notify Compliance Officer	By 29 July 2026
Conduct CDD on all clients	From 1 July 2026
Screen against DFAT sanctions list	From 1 July 2026 (ongoing)
Train all relevant staff	Before 1 July 2026 for existing staff
Keep records for 7 years	From 1 July 2026 (ongoing)
File SMRs and TTRs as required	Ongoing from 1 July 2026
Annual Compliance Report	First due 31 March 2027

Source: AUSTRAC obligations overview

For the full picture, read our complete guide: AUSTRAC Tranche 2 real estate: the complete compliance guide for agencies.

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