Do real estate agents need to register with AUSTRAC?

Yes, if your real estate agency acts on property purchase or sale transactions. This includes vendors' agents, buyers agents, and buyers advocates acting on purchases. Acting on a transaction means acting as an agent in the execution of a purchase or sale — not merely advertising a property or managing a rental. Residential property managers who only provide leasing, rent collection, and maintenance services and do not act on purchase or sale transactions are generally not reporting entities.

What AML program does a real estate agency need?

Real estate agencies must implement an AML/CTF program covering a risk management framework (including ML/TF risk assessment, compliance officer, transaction monitoring, staff training) and customer due diligence procedures (for buyers, sellers, and beneficial owners). AUSTRAC no longer requires these to be structured as separate labelled 'Part A'/'Part B' sections — you can organise your program as suits your business. The program must specifically address property transaction risk factors including payment source verification, international buyers, and high-value transactions.

What counts as a designated service for a real estate agent?

Acting as a real estate agent in a transaction for the sale or purchase of real property is the designated service — this covers vendors' agents, buyers agents, and buyers advocates. Property developers selling directly to buyers can also be captured in some circumstances, and agencies handling both residential and commercial transactions are in scope for both. The obligation attaches to the act of transacting, not to advertising a listing.

What is NOT captured under Tranche 2 for real estate?

Residential property managers who only provide leasing, rent collection, and maintenance are generally out of scope, as are strata managers, property valuers, mortgage brokers (already regulated under Tranche 1), and real estate auctioneers acting on behalf of agents. If your agency runs both sales and property management, only the sales side carries the reporting obligation — but that still means the whole agency needs a program covering how the two are kept separate.

How much does AUSTRAC compliance cost for real estate agents?

The government's Regulation Impact Statement estimated significant ongoing compliance costs for small businesses — covering staff time, external advice, and software. Boutique AML consultants typically charge $8,000–$50,000 for a real estate agency program. Klyvon is purpose-built for Australian real estate agents and generates a firm-specific AML/CTF program in one session, at a fraction of that cost.

What happens if a real estate agent doesn't comply now that obligations are in effect?

Operating as a reporting entity without an AML/CTF program and CDD procedures, now that obligations commenced 1 July 2026, is a contravention of the AML/CTF Act 2006. Civil penalties can reach $36,400,000 per contravention for bodies corporate (real estate agencies operating as companies), based on the penalty unit rate of $364 effective 1 July 2026. Non-enrolment after 29 July 2026 attracts daily penalties of up to $21,840. In addition to AUSTRAC penalties, estate agents may face consequences under state real estate licensing frameworks.

Can real estate agents use AI to generate their AML program?

Yes. Klyvon is purpose-built for Australian real estate agents — it generates a firm-specific AML/CTF program in one session. The AI is prompted with AUSTRAC's published Real Estate Starter Kit and sector guidance as context. The generated program covers your risk framework and CDD procedures specific to property transactions, including verification of buyers, sellers, and beneficial owners of corporate clients. The program must be reviewed and adopted by your compliance officer before implementation.

How often must a real estate agency get an independent evaluation of its AML/CTF program?

At least once every 3 years, and more often if appropriate to the size and complexity of the agency. This is a separate, mandatory requirement under the AML/CTF Act — distinct from the agency's annual internal program review. The independent evaluation must assess the agency's ML/TF risk assessment, the design of its AML/CTF policies, its actual compliance with those policies, and whether it's appropriately identifying, assessing, and mitigating ML/TF risk. Findings go in a written report to the agency's governing body or a responsible senior manager.

Obligations are in effect·Enrolment deadline: 29 July 2026—10 days remaining

Updated July 2026

Field Guide · Real Estate Agents

Every deal you close is now a compliance event.

AUSTRAC Tranche 2 obligations for Australian real estate agents — who's captured, what CDD to run before exchange, and how to comply now that the rules are live.

Build your program with Klyvon →See red flags

1 Jul 2026
Obligations commenced: 29 Jul 2026
Enrolment deadline: $36.4M
Max civil penalty: 3 yrs
Independent review cycle

In this guide

Who is captured, and who isn't Red flags in property transactions CDD checklist for every deal Why real estate is a priority target Frequently asked questions Build your program with Klyvon

I. The Line AUSTRAC Draws

Advertising a listing is nothing. Acting on the sale is everything.

ince 1 July 2026, Australian real estate agents who act on property purchase or sale transactions are AUSTRAC reporting entities under the AML/CTF Amendment Act 2024 — and these obligations are now in effect, not pending. The trigger isn’t the size of the agency or the value of the property. It’s whether you act as agent in the execution of a purchase or sale.

That distinction matters because so much of an agency’s work sits outside it. Vendors’ agents, buyers agents, and buyers advocates acting on purchases are all captured — as are property developers selling directly to buyers in some circumstances, and agencies handling commercial as well as residential transactions. Residential property managers who only lease, collect rent, and arrange maintenance generally fall outside the regime, along with strata managers, valuers, and mortgage brokers, who were already regulated under Tranche 1.

“Acting as a real estate agent in a transaction for the sale or purchase of real property is a designated service — it doesn’t matter what the property is worth.”
— AUSTRAC Real Estate Starter Kit

II. What AUSTRAC Watches For

Eight patterns that show up in property deals

Any one of these can have an innocent explanation — a genuine all-cash buyer exists. What matters is whether, taken together, a reasonable agent in your position would start to wonder.

All-cash purchase

A buyer who wants to settle entirely in cash, with no finance trail to check against.

Offshore entities or funds

Purchase money routed through overseas companies, trusts, or accounts with no clear commercial reason.

Rapid buy-sell cycles

A property bought and resold within a short window, often at an unexplained price jump.

Price far from market

A sale price significantly above or below comparable properties, with no obvious reason.

PEP in the picture

A politically exposed person, or someone closely connected to one, appears as buyer, seller, or beneficial owner.

Layered ownership

Shell companies, trusts, and nominee arrangements stacked with no commercial rationale.

Third-party funding

Someone other than the named buyer is quietly providing the purchase funds.

Reluctance on paperwork

A client who resists standard verification, or wants the deal to move faster than due diligence allows.

III. Before You Act On Anything

Five things to verify on every transaction

Run through these for every buyer and seller you act for — individual, company, or trust — before you act on their behalf, not after the deal is already moving.

Individual buyers and sellers

Start with the basics — full name, date of birth, residential address — but don't take a driver's licence at face value. You need to verify each of those details against a reliable, independent source: a current government-issued photo ID plus a secondary document. Do this early in the relationship, not the week contracts are due to exchange.

Company buyers and sellers

When the party on the contract is a company, the company itself needs verifying against ASIC records — but that's only the first layer. You also need to identify and verify every beneficial owner: anyone holding more than 25% ownership or effective control, even if their name never appears on the contract of sale.

Trusts and family structures

Property deals routinely run through trusts, and trusts hide the real parties by design. Identify the trustee, the settlor, and every beneficiary, and verify the trust deed where you can get hold of it. Discretionary trusts with layered or shifting beneficiary classes call for enhanced due diligence — don't accept a one-line trust summary at face value.

Source of funds

For high-value transactions, or wherever the money's origin doesn't line up with what you know about the client, document where the purchase funds actually came from. A vague answer about 'savings' on a multimillion-dollar cash purchase is exactly the kind of gap AUSTRAC expects you to have pressed on.

Politically exposed persons

Screen every buyer and seller for PEP status — a current or former senior government official, or an immediate family member of one. If you get a hit, the file moves to enhanced due diligence automatically; it isn't optional and it isn't something a junior team member can wave through.

Where CDD sits against a property transaction

Client engaged

Exchange

CDD must be done

Settlement

Too late to start CDD

Identity and beneficial-ownership verification has to be substantially complete before contracts exchange — not squeezed in during the settlement countdown. Waiting until settlement week to ask a buyer for ID is the single most common CDD failure AUSTRAC’s real estate guidance flags.

IV. Why This Sector, Why Now

Australian real estate has been a target for years — the reporting obligation is new, the risk isn't

AUSTRAC and the Australian Criminal Intelligence Commission have long flagged residential property as a high-risk laundering channel — high transaction values, complex ownership structures, and a steady flow of international buyers make it a natural fit for moving illicit funds through a legitimate-looking asset. Tranche 2 doesn’t change that risk profile; it just makes agents responsible for watching it. AUSTRAC’s sector guidance specifically calls out all-cash purchases, offshore entities or funds, rapid buy-sell cycles, and prices well off market as signals that warrant a closer look before you proceed.

V. Reference

Everything else people ask

VI. How Klyvon Helps

Generate your real estate AML/CTF program in one session

Property-specific program

Built on AUSTRAC's Real Estate Starter Kit and sector guidance — covers your risk framework and CDD procedures for buyers, sellers, and beneficial owners.

Reviewed by your CO

The draft is a starting point for review by your compliance officer before adoption. All decisions and implementation remain with your agency.

Built on current law

Every draft reflects the AML/CTF Act 2006 and current AUSTRAC guidance for real estate agents.

Answers instead of pointing you at a PDF

No other Tranche 2 platform in Australia does this.

Get started free →

Free to start · cancel anytime

Related resources

Real Estate Guide

Full sector guide and 7-step checklist

AUSTRAC Tranche 2 — Complete Guide

Obligations, deadlines, penalties

AUSTRAC Penalty Register

Enforcement actions and penalty figures

Am I Regulated?

Quick scope check for your business

AML Compliance Cost Australia

What consultants charge vs. Klyvon

All resources

Every guide, sector explainer and tool