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What is Tranche 2 and why does it affect real estate agents?

The short version

From 1 July 2026, real estate agents in Australia must comply with anti-money laundering and counter-terrorism financing (AML/CTF) laws. This is known as “Tranche 2” of the reforms.

If your agency brokers the purchase, sale, or transfer of property for clients, you are affected. Property management and leasing are not covered.

Who is AUSTRAC?

AUSTRAC is Australia’s financial intelligence agency and AML/CTF regulator. They oversee compliance for banks, gambling operators, and — from July 2026 — real estate agents.

AUSTRAC has been clear: the deadline is fixed and will not be extended.

Why is this happening now?

The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 passed in November 2024. It brings Australian real estate agencies in line with international standards. Real estate has been identified as a sector vulnerable to money laundering — through large cash transactions, complex ownership structures, and rapid property purchases.

What you need to have in place

By 1 July 2026, your agency needs to:

  • Enrol with AUSTRAC via AUSTRAC Online (enrolment opens 31 March 2026; deadline 29 July 2026)
  • Build an AML/CTF program — documented policies covering risk assessment, CDD, screening, and reporting
  • Appoint a Compliance Officer at senior management level
  • Train your staff on AML/CTF risks and your agency’s procedures

From 1 July 2026, ongoing obligations include:

  • Customer Due Diligence (CDD) — verifying the identity of buyers and sellers before you provide your service
  • Sanctions screening — checking clients against the DFAT consolidated sanctions list
  • Suspicious Matter Reports (SMRs) — reporting to AUSTRAC when you have reasonable grounds to suspect money laundering or terrorism financing
  • Record keeping — retaining AML/CTF records for at least 7 years
  • Annual Compliance Reports — first report covers 1 July – 31 December 2026, due 31 March 2027

What AML Simple does

AML Simple is a workflow tool that helps you build your program, manage CDD, run sanctions screening, and keep records in one place. It does not provide legal or regulatory advice — it helps you work through each requirement in a structured and documented way.

For full AUSTRAC guidance, visit austrac.gov.au.