New AML Obligations Coming In This Year: What Property Firms & Clients Need to Know

From 1 July 2026, Australia’s real estate sector will be at the centre of one of the most significant regulatory changes in recent decades as anti-money laundering (AML) and counter-terrorism financing (CTF) laws are expanded to cover agents, developers and other property professionals. The reforms are part of a federal effort to close long-standing gaps in the AML/CTF framework and align domestic law with global standards set by the Financial Action Task Force (FATF). 

Who Is Affected?

Under the AML/CTF Amendment Act 2024, a broad range of property market participants — previously outside the formal AML regime — will be classified as “Tranche 2” reporting entities and subject to new compliance obligations. This includes:

• Real estate professionals such as agents, buyer’s agents and property developers who broker sales or sell properties directly;
• Conveyancers and lawyers involved in planning or executing property transfers;
• Other professional service providers connected to property transactions.  

The reforms recognise that real estate transactions can be exploited for money laundering because they often involve large sums and complex ownership structures, making it easier for illicit funds to be integrated into the legitimate economy. 

Key Obligations for Real Estate Businesses

From the compliance start date of 1 July 2026, property professionals will need to meet a suite of AML/CTF obligations that go far beyond traditional sales processes:

🔹 Enrolment with AUSTRAC

Businesses providing designated real estate services must enrol with the Australian Transaction Reports and Analysis Centre (AUSTRAC) and, where required, register as reporting entities within set timeframes. 

🔹 AML/CTF Program Development

Real estate agencies and developers must establish and maintain a risk-based AML/CTF program, tailored to their business. This includes appointing a compliance officer and documenting internal controls. 

🔹 Customer Due Diligence (CDD)

One of the most transformative requirements will be Know Your Customer (KYC) and CDD checks for all clients in a transaction. Agents must verify identity, understand beneficial ownership, assess source of funds and, where necessary, perform enhanced due diligence on higher-risk clients. 

🔹 Reporting and Monitoring

Real estate businesses will be required to monitor transactions for suspicious activity and report certain threshold transactions or suspicious matters to AUSTRAC. This effectively brings them into the same reporting regime long in place for banks and financial institutions. 

🔹 Record Keeping

Detailed records of verification, transactions, risk assessments and compliance activities must be maintained — typically for at least seven years. 

Preparing for the Transition

AUSTRAC opened enrolment for new reporting entities on 31 March 2026, giving real estate businesses a narrow window to begin compliance preparations ahead of the July deadline. Sector-specific guidance and “starter kits” to help meet obligations are being released to support the transition. 

Industry advisers are urging property professionals to begin early preparations, including reviewing internal processes, onboarding training, and assessing business models to determine whether sales handled via third parties may exempt certain developers from regulation. 

Industry Impact and Outlook

For many in the real estate industry, the reforms represent a seismic shift. Agents and developers will need to balance traditional sales and marketing functions with ongoing compliance activities more commonly associated with banks and financial service providers.

Critics of past AML frameworks have pointed to the exploitation of property markets as a conduit for laundering illicit funds, with reports over the years highlighting real estate’s vulnerability — particularly in luxury and high-value transactions. The new laws aim to make the sector less attractive to criminals and more transparent for legitimate activity. 

However, the added compliance costs, training requirements, and reporting duties are expected to be met with concern by some smaller agencies and independent operators. Many industry voices are currently focused on understanding the practical implications of KYC checks and how these will be integrated into everyday transaction workflows without damaging client experience. 

As 1 July 2026 approaches, real estate professionals across Australia are being urged to act now to understand and implement the necessary AML/CTF frameworks — both to avoid penalties and to play their part in a more transparent, integrity-driven property market. 

Why It Matters for Clients

For vendors and buyers, this won’t change how you sell or buy — but it will influence how your information is verified and why agents may ask for additional documentation. The aim is to better protect the integrity of property markets and deter illicit financial activity.

As these obligations come into force, your real estate professional will be able to guide you through any additional requirements well ahead of closing dates.