Does property management trigger AML Tranche 2?

Pure rent collection is generally lower-risk and may not be a designated service, but involvement in buying, selling, or transferring property for a client is captured. Check your exact services with the scope checker.

Do small or single-office agencies have to comply?

Yes. Capture depends on the services you provide, not your size. A single-agent office that handles property sales is fully in scope and must enrol.

What's the penalty for not enrolling?

Up to $19,800 per day in civil penalties, and you're operating unlawfully if you provide designated services without enrolment. Enrol before the 29 July 2026 deadline.

AML Tranche 2 for real estate agents: the complete compliance checklist

Real estate is the largest sector captured by AML/CTF Tranche 2 from 1 July 2026. This checklist covers enrolment, your AML/CTF program, customer due diligence, reporting, and the deadlines that matter.

Are real estate agents captured?

Yes. Real estate is the largest single sector brought into the AML/CTF regime by Tranche 2 from 1 July 2026. If you provide real-estate agency services — acting for a buyer or seller, conducting auctions, or arranging property transactions — you provide a "designated service" and become an AUSTRAC reporting entity.

Property management alone (collecting rent) is generally lower-risk, but the moment you're involved in buying, selling or transferring real estate for a client, you're in scope. Confirm your exact position with the AML Tranche 2 scope checker.

Key dates

31 March 2026 — AUSTRAC enrolment opens
1 July 2026 — AML/CTF obligations commence (program, CDD, monitoring, reporting all live)
29 July 2026 — enrolment deadline for the first wave

Miss enrolment and you face up to $19,800 per day in civil penalties — and you're operating illegally if you provide designated services without being enrolled.

Step 1 — Enrol with AUSTRAC

Enrolment is free, via AUSTRAC Online. You'll need your entity details, beneficial-owner details, a nominated AML/CTF Compliance Officer, and your drafted program. Full walkthrough: AUSTRAC enrolment guide.

Step 2 — Build your AML/CTF program

Two parts, both board-approved (or principal-approved for sole traders):

Part A — the risk-based framework: your money-laundering/terrorism-financing risk assessment, governance, training, transaction-monitoring approach, and oversight
Part B — your customer due diligence procedures: how you identify and verify customers, beneficial owners and PEPs

AUSTRAC publishes a real-estate starter template — tailor it to your agency's risks, don't lodge it as-is.

Step 3 — Customer due diligence

Before providing a designated service to a new client, you must:

Collect and verify the customer's full name, date of birth and address
Identify beneficial owners — any individual owning or controlling ≥25% (use the beneficial owner identifier for companies, trusts and SMSFs)
Screen for politically exposed persons (PEPs)
Assess and document the ML/TF risk of the customer

Step 4 — Monitoring + reporting

Suspicious Matter Reports (SMRs) — within 24 hours of forming a suspicion. Tipping off the customer is a separate criminal offence.
Threshold Transaction Reports (TTRs) — any cash transaction of $10,000 or more, within 10 business days.
Ongoing monitoring — keep transaction and CDD records for 7 years.

The full checklist

Confirm capture with the scope checker
Appoint an AML/CTF Compliance Officer with real authority
Draft Part A + Part B program (tailor the AUSTRAC template)
Enrol with AUSTRAC before 29 July 2026
Build your CDD workflow — identity, beneficial ownership, PEP screening
Set up transaction monitoring + SMR/TTR lodgement access in AUSTRAC Online
Train all relevant staff (and keep training records)
Establish 7-year record-keeping
Schedule the annual independent review
Add every AML deadline to your calendar via the compliance calendar tool

See the complete picture, including enforcement examples, in the AML Tranche 2 hub. This is general information, not legal advice — confirm your obligations with AUSTRAC or an AML lawyer.