Countdown: Make Your Agency AML/CTF Compliant Before July 2026

Australia’s Anti-Money Laundering And Counter-Terrorism Financing Laws

Introduction

Australia’s AML/CTF laws have expanded, requiring property professionals to comply from 1 July 2026. Businesses must have effective systems in place to monitor, report, and mitigate risks associated with money laundering and terrorism financing. AgentSafe can help you meet these obligations efficiently, with tools designed for property management compliance. Learn more about AgentSafe.

Understanding Your Obligations

As a real estate professional, you are responsible for conducting customer due diligence, verifying identities, and maintaining auditable records of transactions. This includes implementing compliance checkpoints for every property under management and ensuring all staff follow the proper procedures.

While the demo video does not show the AML/CTF functionality, it highlights other key areas that could be exploited by criminals and demonstrates how AgentSafe’s workflow manages compliance risks effectively. See how AgentSafe works.

How AgentSafe Supports Compliance

AgentSafe makes all of this simple and auditable, providing a central dashboard for property compliance and automated reporting, so your business can track, document, and demonstrate compliance with ease. Explore AgentSafe benefits.

Why Compliance Matters

Failing to comply with AML/CTF laws can result in significant fines and reputational damage. The industry is under increased scrutiny, and using the right tools ensures you can demonstrate compliance quickly and reliably. AgentSafe not only helps you meet legal obligations but also supports operational efficiency across your portfolio.

Call to Action

Ensure your business is ready for AML/CTF compliance from 1 July 2026. Discover how AgentSafe automates reporting, monitors property risks, and stores all required documentation securely.

Tranche 2 AML/CTF Reforms Commence 1 July 2026

From 1 July 2026, real estate agents, buyers’ agents, property developers, and associated professional service providers will be regulated under Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime as Tranche 2 reporting entities.

AML/CTF compliance is no longer a future planning issue — it is an operational readiness issue.

AUSTRAC has been clear:

  • the risk is real

  • the sector is exposed

  • preparation is expected before the laws commence

What separates businesses now is not awareness — it is execution.

Why Real Estate Is a Priority Sector

Australia’s economy continues to be exploited by serious and organised crime. Legitimate businesses are used to disguise illicit funds, which are then reinvested into further criminal activity including fraud, scams, drug trafficking, child exploitation, and terrorism financing.

AUSTRAC’s Money Laundering in Australia – National Risk Assessment 2024 confirmed that:

  • Domestic real estate presents a very high money laundering risk

  • Real estate services are widely exploited by criminal networks

  • Complex ownership structures, third-party arrangements, and high-value assets make property attractive for laundering illicit funds

These findings are the primary reason real estate services are now regulated under Tranche 2.

Tranche 2: What Changes on 1 July 2026

Under the amended AML/CTF Act, AUSTRAC regulation expands to include designated services typically provided by:

  • Real estate agents

  • Buyers’ agents

  • Property developers

  • Lawyers, conveyancers, and accountants

  • Dealers in precious stones, metals, and luxury goods

Tranche 2 entities may enrol with AUSTRAC from 31 March 2026, but compliance obligations apply from 1 July 2026. There is no transitional enforcement grace period.

Awareness Is No Longer the Issue

AML/CTF is already being covered in CPD. AUSTRAC has run webinars and published guidance. Preparation timelines have been clearly communicated. Compliance tools exist in the marketplace.

The remaining risk is fragmented, patchwork compliance — spreadsheets, disconnected documents, generic AML manuals, and undocumented assumptions. That approach will not withstand audit scrutiny.

What AUSTRAC Will Expect to See

Once enrolled, your business becomes a reporting entity and must be able to demonstrate, at any time, that it has:

  • A documented, risk-based AML/CTF program

  • A nominated compliance officer

  • Customer due diligence (CDD) procedures

  • Ongoing monitoring and risk assessment

  • Proper record-keeping and audit trails

  • Timely reporting to AUSTRAC

  • Staff who understand their operational role

Compliance is judged on outcomes and evidence, not intent.

AML/CTF in Real Estate Is Property-Centric

For real estate businesses, AML/CTF risk does not sit neatly with one “customer”.

Properties commonly involve:

  • buyers and sellers

  • tenants and landlords

  • lot owners

  • tradespeople and contractors

  • multiple agencies

While customer due diligence may sometimes be confined to each agent’s own client — for example, where a buyers’ agent conducts due diligence on the buyer and the selling agent conducts due diligence on the seller — active enquiries must still be made and recorded where other connected parties are involved in the transaction.

Lot owners, particularly in strata, community title, and investment properties, may:

  • have legal or beneficial ownership of a property

  • contribute to payments or levies that are managed through trust accounts

  • be part of complex ownership or trust structures

For AML/CTF compliance, agencies must:

  • Record and maintain ownership details for all landlords, vendors, and lot owners

  • Identify and verify buyers and tenants, including source of funds, noting that lot owners are a source of funds in strata and ownership-related arrangements

  • Make active and reasonable enquiries when relying on another party’s customer due diligence

  • Maintain a clear, documented audit trail of verification information, enquiries, and decisions

This ensures a complete, defensible AML/CTF record.

From KYC to Know Your Property (KYP)

An effective AML/CTF program for real estate must incorporate a Know Your Property (KYP) framework, integrating:

  • buyers and sellers

  • landlords and tenants

  • lot owners (including beneficial owners and source-of-funds verification where applicable)

  • tradespeople and contractors

Material Fact Disclosure Reporting is a core part of KYP, providing:

  • a history of compliance and accountability by the owner

  • critical information for AML/CTF review

  • inputs for property compliance reports sent to owners

KYP ensures all parties with legal, financial, or operational connections to a property are properly identified, assessed for risk, and documented, aligning AML/CTF with operational and WHS obligations.

Integrating WHS and AML Risk

AML/CTF risk assessment should not occur in isolation. Property inspections and WHS walk-throughs:

  • protect staff and visitors

  • identify discrepancies in owner declarations

  • uncover hazards linked to criminal activity (e.g., drug manufacturing, unsafe alterations)

These inspections form a critical part of both AML/CTF and WHS compliance, particularly where suspicious activity creates safety risks.

Trust Account Management and Transaction Monitoring

AgentSafe provides an integrated trust account workflow that enables the recording and monitoring of key financial transactions, including:

  • Deposit paid or settlement payment recorded

  • Rent paid

  • Payments of levies

Each transaction can be linked to:

  • Property-specific risk notes (for example, an owner-provided invoice used to evidence the source of funds for renovations)

  • Verification of relevant parties (buyer, seller, landlord, tenant, or lot owner)

  • Transaction details, including transaction type, transaction status, property address, transaction date, and amount

This ensures transparency and AUSTRAC-ready reporting, integrating operational and AML risk in one workflow.

How AgentSafe Supports AML/CTF Readiness

AgentSafe is a property-focused compliance platform, designed specifically for real estate operations. It provides:

  • Buyer, seller, landlord, tenant, and lot owners recording

  • Connected-party risk awareness (including tradespeople and contractors)

  • Active enquiry documentation

  • Property-linked AML and KYP records

  • Material Fact Disclosure reporting for audit and compliance history

  • Repairs and maintenance management workflow, including contractor licence and insurance verification, completion tracking, and tagging of all relevant information — including property, customer, and text notes — directly into the compliance report submitted to AUSTRAC

  • Secure document retention

  • Audit-ready reporting

  • Trust account workflow with all transaction, property, and customer information tagged directly into the compliance report submitted to AUSTRAC

Additional features:

  • TrueVault ID Verification (from January 2026) – an alternative to manual ID verification, reducing storage needs while maintaining strict privacy

  • ADL Forms with auto-populated addresses – saving time and reducing errors in documentation

  • Information source links to legislation – provided before creating jobs, ensuring staff follow regulatory guidance

AML/CTF features roll out from December 2025, enabling:

  • staff training

  • operational testing

  • system familiarisation

  • well ahead of the 1 July 2026 compliance commencement

Countdown to Compliance

  • Businesses that invest in systems now will transition smoothly.

  • Businesses relying on last-minute fixes will struggle.

  • Businesses doing nothing will face serious regulatory exposure.

AgentSafe is built for agencies that take AML/CTF seriously.

Compliance Reminder

If a party has an ownership or financial interest in the property — including lot owners, additional buyers, or investors purchasing together — record their interest and verify the source of funds where applicable. Capture this, along with material fact disclosures and transactions, in AgentSafe to maintain a complete AML/CTF and property compliance record.