For the first time, every Australian real estate practice will be a reporting entity. You will need an AML/CTF program, customer due diligence on the parties to a transaction, beneficial-ownership identification for any corporate buyer, and a written suspicious-matter reporting process. This page explains what changes for residential sales, commercial transactions, and off-the-plan deals.
AUSTRAC enrolment opens 31 March 2026 and is mandatory before you can lawfully provide a designated service after 1 July 2026. The biggest operational change is customer due diligence at the start of the engagement: you collect and verify identity on the buyer (and on the seller in many cases), identify beneficial owners where a corporate or trust entity is involved, and screen against sanctions lists. Trust-account flows are no longer a back-office matter, every deposit, settlement, and refund becomes a transaction-monitoring event. The agency principal is responsible for the program; the day-to-day work typically falls to a designated AML/CTF Compliance Officer.
Source-of-funds enquiry is now standard practice, not optional. If the buyer cannot evidence the source of the deposit and the balance, the transaction is a candidate for a Suspicious Matter Report regardless of whether the contract proceeds.
Beneficial-ownership identification means tracing through the corporate structure to the natural persons who ultimately control the buyer. The 25% ownership threshold is a starting point, not a ceiling, anyone with effective control must be identified.
Enhanced customer due diligence applies. Source of wealth and source of funds must be documented, the customer relationship requires senior-management sign-off, and ongoing monitoring is tighter throughout the transaction.
When the depositor is not the buyer named in the contract, you collect identification on the depositor too, document the rationale for the third-party payment, and assess the pattern for SMR triggers.
Every real estate principal must enrol as a reporting entity. Enrolment opens 31 March 2026; completion before 1 July 2026 is the lawful pathway to continue providing designated services.
Part A documents how the agency identifies and manages ML/TF risk. Part B sets out the customer identification procedures. Senior-management approval and an annual review are mandatory.
Identity collection and verification on the buyer (and frequently the seller). Verification uses reliable independent sources, Document Verification Service is the Australian standard.
For corporate or trust buyers, identify and verify the natural persons who ultimately own or control the entity. The 25% test is a threshold; effective control extends below it.
Monitor transactions and customer behaviour for unusual patterns. File SMRs to AUSTRAC within 3 business days of forming a suspicion (24 hours for terrorism financing).
Customer identification records, transaction records, and training records must all be retained for 7 years and remain retrievable for AUSTRAC information requests.
Every reporting entity submits a compliance report covering the calendar year, due 31 March of the following year. Nil-activity entities still submit.
Drafts the AML/CTF program from your agency template, captures the customer-due-diligence evidence at point-of-engagement (no rummaging through file notes later), and prepares the annual AUSTRAC compliance report from the audit trail. Runs inside your tenancy, client identification records and transaction data stay on your infrastructure.
Every claim on this page draws on the AUSTRAC published guidance for Tranche 2 entities, plus the sector-specific commentary listed below.
Twenty-five questions, an inline readiness percentage, and a personalised PDF report mapped to real estate obligations. Free, no commitment, no demo required.
This assessment provides general information about Tranche 2 obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). It is not legal advice. For your specific obligations, consult an AML/CTF compliance professional.