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

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 opened
• 1 July 2026 — AML/CTF obligations commenced (program, CDD, monitoring, reporting all live)
• 29 July 2026 — enrolment due for agencies providing designated services from 1 July 2026 (otherwise 28 days after your first designated service)
• 28 August 2026 — AUSTRAC began issuing notices to apparently unenrolled real estate agents

Each day you provide a designated service while unenrolled can be a separate contravention. AUSTRAC can issue an infringement notice of $21,840 (company) or $4,368 (individual) per contravention, or seek a civil penalty of up to $36.4M (body corporate), maximum per contravention.

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

Under the reformed Act your program has two elements (they replaced the former Part A / Part B structure), approved by your governing body or senior manager (the principal, for sole traders):

• ML/TF risk assessment — your agency's money-laundering/terrorism-financing risks by customer, service, delivery channel and jurisdiction
• AML/CTF policies — how you mitigate and manage those risks: governance, the compliance officer, personnel due diligence and training, customer due diligence (identifying and verifying customers, beneficial owners and PEPs), transaction monitoring, reporting and record keeping

Your whole program must be independently evaluated at least once every 3 years; for newly regulated agencies the first evaluation is due between 30 June 2029 and 31 December 2030, depending on your AUSTRAC account number.

Privacy Act. As an AML/CTF reporting entity, your agency is covered by the Privacy Act for its AML/CTF activities even under $3M turnover (Privacy Act 1988 s6E(1A)) — so the ID documents you collect for CDD must be handled under the Australian Privacy Principles.

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

When you broker a sale, purchase or transfer of real estate, both the buyer and the seller are your customers (AML/CTF Act s 6, table 5, item 1) — even if you act only for the vendor. AUSTRAC's real estate guidance confirms you have AML/CTF obligations in relation to both parties. Real estate CDD can be delayed, but must be completed by the earlier of 28 days after exchange or 3 days before settlement (Rules r 6-32(4)).

For each customer, 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 3 business days of forming a suspicion (24 hours for terrorism financing). 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

1. Confirm capture with the scope checker
2. Appoint an AML/CTF Compliance Officer with real authority
3. Draft your ML/TF risk assessment + AML/CTF policies (tailor the AUSTRAC starter kit)
4. Enrol with AUSTRAC — now, if you have not (due 28 days after your first designated service)
5. Build your CDD workflow — identity, beneficial ownership, PEP screening
6. Set up transaction monitoring + SMR/TTR lodgement access in AUSTRAC Online
7. Train all relevant staff (and keep training records)
8. Establish 7-year record-keeping
9. Schedule independent evaluations (at least every 3 years; first due 30 June 2029 – 31 December 2030)
10. 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.