Obligations commence: 1 July 2026·Enrolment deadline: 29 July 2026—27 days remaining
AML/CTF Compliance · Real Estate Agents Australia
AML compliance for real estate agents in Australia — AUSTRAC Tranche 2
From 1 July 2026, Australian real estate agents acting on property purchase or sale transactions become AUSTRAC reporting entities under the AML/CTF Amendment Act 2024. This guide covers who is captured, what the CDD requirements are for property transactions, and how to comply. For the full industry guide see /real-estate.
Written by the Klyvon Compliance Team · Melbourne, Australia · General guidance only, not legal advice
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Who is captured — and who is not
Captured (reporting entity)
✓ Vendors' agents acting on property sales
✓ Buyers agents acting on property purchases
✓ Buyers advocates
✓ Property developers selling directly to buyers (in some circumstances)
✓ Agents handling both residential and commercial transactions
NOT captured
✗ Residential property managers (leasing only)
✗ Rent collection and maintenance services
✗ Strata managers
✗ Property valuers
✗ Mortgage brokers (already Tranche 1)
✗ Real estate auctioneers acting on behalf of agents
Source: AML/CTF Act 2006, s.6(5B) Table 6; AUSTRAC Real Estate Guidance 2026.
Property transaction CDD — what you must verify
For every property purchase or sale transaction, you must conduct customer due diligence before acting on behalf of the client. The specific requirements:
Individual buyers and sellers
Full name, date of birth, and residential address. Verify using reliable, independent source documents (government-issued photo ID + secondary document).
Company buyers and sellers
Verify the company via ASIC records. Identify and verify all beneficial owners — individuals with more than 25% ownership or effective control.
Trust structures
Identify the trustee, settlor, and all beneficiaries. Verify the trust deed where possible. Enhanced due diligence for discretionary trusts with multiple beneficiary classes.
Source of funds
For high-value transactions or where the source of funds is unclear or inconsistent with the client's profile, document the source of purchase funds.
Politically exposed persons (PEPs)
Apply enhanced due diligence to any buyer or seller who is a current or former senior government official or their immediate family member.
Why real estate is a high-priority AUSTRAC target
Australian residential real estate has long been identified by AUSTRAC and the Australian Criminal Intelligence Commission (ACIC) as a high-risk sector for money laundering. The combination of high transaction values, complex ownership structures, and international buyers creates significant ML/TF risk. AUSTRAC's Tranche 2 real estate guidance specifically highlights: all-cash purchases, transactions involving offshore entities or funds, rapid buy-sell cycles, and transactions significantly below or above market value as red flags requiring enhanced scrutiny.
Frequently asked questions
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. Source: AML/CTF Act 2006, s.6(5B) Table 6.
What AML program does a real estate agency need?
Real estate agencies must implement an AML/CTF program with Part A (risk management framework including ML/TF risk assessment, compliance officer, transaction monitoring, staff training) and Part B (customer due diligence procedures for buyers, sellers, and beneficial owners). The program must specifically address property transaction risk factors including payment source verification, international buyers, and high-value transactions. Source: AML/CTF Act 2006, ss.81–85; AUSTRAC Real Estate Starter Kit 2026.
How much does AUSTRAC compliance cost for real estate agents?
The Australian Government's Regulatory Impact Statement estimated $23,250 average one-time preparation cost using external consultants. Boutique AML consultants charge $5,000–$15,000 for real estate agency programs. Klyvon is purpose-built for Australian real estate agents — it generates a firm-specific AML/CTF program in 60 seconds from $79/month, with a 7-day free trial.
What happens if a real estate agent doesn't comply by July 2026?
Operating as a reporting entity without an AML/CTF program and CDD procedures from 1 July 2026 is a contravention of the AML/CTF Act 2006. Civil penalties can reach $33,000,000 per contravention for bodies corporate (real estate agencies operating as companies). Non-enrolment after 29 July 2026 attracts daily penalties of up to $18,780. 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 60 seconds from $79/month. The AI is trained on AUSTRAC's published Real Estate Starter Kit and sector guidance. The generated program covers Part A (risk framework) and Part B (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.
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General guidance only · Not legal advice · Source: AML/CTF Act 2006, s.6(5B) · austrac.gov.au