What changed on 1 July 2026
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 brought real estate professionals under AUSTRAC's AML/CTF regime as part of Tranche 2. Enrolment opened 31 March 2026, obligations commenced 1 July 2026, and agencies already providing designated services on that date had to enrol with AUSTRAC by 29 July 2026.
Which real estate activities are designated services?
An agency is captured when it acts in relation to the sale, purchase or transfer of real estate. The typical designated-service touchpoints for selling agents are:
- Marketing a property for a vendor
- Introducing a purchaser to a vendor
- Preparing or facilitating a contract of sale
- Receiving or holding deposit funds in trust
- Assisting with property transfers between related parties
- Managing off-market or private-treaty sales
Note: property management (leasing / rentals) is generally nota designated service. If your agency does both sales and property management, only the sales side is captured. Buyers' agents have distinct obligations, see the buyers' agents page.
What your agency must do
Enrol via AUSTRAC Online
You will need your ABN, the state real estate licence number for every jurisdiction your agency operates in (REI licence, estate agent authority, Property Occupations licence, the label varies by state), a list of the sales-side designated services you provide, and your Compliance Officer’s details. Franchise offices generally enrol as separate reporting entities from the group. Existing agencies had to enrol by 29 July 2026; new agencies within 28 days of the first captured listing or exchange.
Verify vendor at listing, purchaser at exchange
Before you sign the listing agreement, verify the vendor’s identity and, for corporate or trust vendors, the beneficial owners at the 25 percent threshold. Before contracts exchange, verify the purchaser and their beneficial owners. At-auction pressure is real: build ID collection into your bidder registration or paddle-number process, not after the hammer falls. Anonymous or last-minute bidders are a red flag, not a sales opportunity.
Build a program around AUSTRAC’s real estate risk assessment
Your program must reflect your actual mix: residential-only vs mixed residential/commercial, on-market vs off-market, single office vs franchise network. AUSTRAC’s real estate sector risk assessment flags off-market and cash-adjacent settlements, premium-segment coastal residential, and multi-layered foreign-controlled corporate purchasers as elevated risk. Your program must address each of those explicitly, not with a generic template.
Rate risk by segment, channel and purchaser type
Segment your Risk Mitigation Plan across property tier (median residential vs premium/luxury vs commercial), sale channel (public auction, private treaty, off-market, expression of interest), and purchaser profile (owner-occupier, domestic investor, corporate/trust, foreign purchaser under FIRB). Refresh whenever you push into a new segment, whether rural, luxury waterfront, off-plan pre-sales, or corporate divestments.
Train every touchpoint, not just principals
Licensed principals, sales representatives, PAs and BDMs who take enquiries, auction callers, off-market negotiators: anyone with a designated-service touchpoint must be trained before they act. Franchise networks: head-office training does not automatically cover new offices’ staff. Track competency by individual, refresh annually, and keep evidence in a form your independent evaluator can pull in one export.
Watch for the sale-specific red flags AUSTRAC lists
SMRs are due within 24 hours if terrorism financing is suspected, otherwise within 3 business days. The pattern-matching AUSTRAC calls out for real estate: purchasers who show no interest in the property itself, cash-adjacent settlements structured just below reporting thresholds, sudden name changes on the buyer side before exchange, and beneficial ownership structures that seem disproportionate to the purchase price. Records retained for 7 years, well past the sunset on your listing agreement.
How AML SoftServe fits a real estate agency
Pricing for real estate agencies
Self-serve plans start at $0/month with per-check KYC/KYB rates, or our team runs case work for you on the fully managed track. Use the plan calculator on the pricing page to find the cheapest option for your volume.
The 29 July enrolment deadline has passed.
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