AML/CTF Tranche 2 is now live, and the maximum penalty just went up

Two things happened on 1 July 2026

Real estate agencies became reporting entities under the AML/CTF Act 2006. Tranche 2 obligations are no longer a countdown. They are current law.

On the same day, the Commonwealth penalty unit rose from A$330 to A$364, under the standard indexation set out in s 4AA of the Crimes Act 1914. That indexation happens periodically regardless of AUSTRAC. This cycle, it landed on the exact day Tranche 2 obligations started for real estate.

Both facts change the calculation for agency principals who haven't started yet.

The fastest way to have a documented starting point today: enter your ABN at AML Simple. The onboarding wizard pulls your registered business details automatically (around 2 minutes), the AUSTRAC Readiness Check shows exactly where your agency stands against the obligations that are now live (around 5 minutes), and the AML/CTF Program Generator produces a program document consistent with AUSTRAC's Program Starter Kit structure (around 15 minutes). Under half an hour to a documented starting point for your program.

Want the full picture of what's now required and why the numbers changed? Here it is.

What commenced on 1 July

Under the Act, real estate agencies providing designated services (acting for a vendor or purchaser in a property sale, among others) are now reporting entities. Reporting entities are required to:

Have a written and approved AML/CTF program
Carry out customer due diligence on clients
Screen against sanctions and PEP lists
Keep records for the required period
Lodge suspicious matter reports and threshold transaction reports when they apply
Nominate an AML/CTF compliance officer

None of this is new information. What changed on 1 July is that these are no longer future obligations. They are the current legal position for every agency handling a sale.

29 July 2026 is the deadline to notify AUSTRAC of your nominated AML/CTF compliance officer and complete enrolment, for agencies that have not yet done so.

Why the penalty unit matters

The Commonwealth penalty unit is the base figure used to calculate civil and criminal penalties across Commonwealth law, including the AML/CTF Act. It's indexed periodically under s 4AA of the Crimes Act 1914. On 1 July 2026, it moved from A$330 to A$364 per unit.

That's roughly a 10% increase applied to every AML/CTF penalty calculation.

Maximum civil penalties are set in penalty units, not dollar figures, so the new unit value flows straight through:

Up to A$36.4 million per contravention for a body corporate (100,000 penalty units)
Up to A$7.28 million per contravention for an individual (20,000 penalty units)

For ongoing non-compliance, such as failing to enrol or maintain a program, daily continuing penalties apply:

Up to A$21,840 per day for a body corporate
Up to A$4,368 per day for an individual

These are the maximum figures the Act allows, not a prediction of what any specific agency would face. AUSTRAC's actual enforcement approach considers the nature and history of a contravention. The point is simpler: the ceiling moved up, and it moved up on the same day the obligations became enforceable for this sector.

What this means in practice

An agency with no program in place on 1 July is not automatically facing the maximum penalty. The figures above are maximums per contravention, not the starting point. AUSTRAC has described its posture towards newly regulated sectors as supportive but firm, working with businesses that are making a genuine effort to comply.

But "the deadline is coming" is a different sentence to say out loud than "the obligation applies now, and the maximum penalty for getting it wrong just went up." Agencies without a compliance officer, a written program, or CDD processes running are currently operating outside a requirement that carries real financial exposure. Waiting doesn't reduce that exposure. It extends the period an agency is exposed to it.

What agencies can do now

For agencies that haven't started:

Confirm your AUSTRAC enrolment status. If you haven't nominated a compliance officer, 29 July is the date to have that done.
Get a documented starting point for your program. A written AML/CTF program is the foundation everything else sits on. One option for agencies is AML Simple, which generates a program document consistent with AUSTRAC's Program Starter Kit structure from a guided wizard.
Start CDD and record-keeping from your next transaction. Obligations run from 1 July forward, not retroactively, but every sale from here needs the process in place.

For agencies that have already built a program: 1 July is a good trigger to confirm your compliance officer nomination is lodged, your CDD workflow is actually running on live transactions (not just documented), and your record-keeping has started.

None of this is legal advice, and AML Simple doesn't provide it. The platform is a workflow tool for building and running your program. For guidance specific to your agency's circumstances, AUSTRAC's own guidance and a qualified AML/CTF professional are the right source.

For the complete list of obligations and how they apply to real estate specifically, read our AUSTRAC Tranche 2 complete guide. If you're still working through enrolment, see how to find your AUSTRAC registration number.