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

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

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, levies, or trust accounts

  • be part of complex ownership or trust structures

For AML/CTF compliance, agencies must:

  • record the ownership details of all lot owners

  • verify the source of funds where applicable

  • make active enquiries when relying on another party’s due diligence

  • maintain a documented audit trail

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 a trust account workflow to track:

  • receipt of deposits, progress payments, and settlement

  • rent collection, bond lodgement, and release

  • payments of purchase price, levies, and outgoings

Each transaction can be linked to:

  • AML/CTF checks

  • property risk assessments

  • buyer, seller, landlord, tenant, or lot owner verification

  • recorded notes and transaction status

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 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 verification, completion tracking, and linking to property compliance reports.

  • Secure document retention

  • Audit-ready reporting

  • Trust account workflow with transaction risk/status tracking

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.

Call-Out Line

If a party has an ownership interest in the property — including lot owners — record their ownership and verify the source of funds where applicable. Capture this, along with material fact disclosures, transactions, and connected-party checks, in AgentSafe for a full AML/CTF and property compliance record.