Tranche 2 deadline: 1 July 2026—40 days remaining
AML/CTF Compliance · Real Estate Agents & Buyers Agents
AUSTRAC Tranche 2 Compliance for Real Estate Agents & Buyers Agents
From 1 July 2026, real estate professionals acting on property transactions in Australia are in scope under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) as amended by the AML/CTF Amendment Act 2024. This includes real estate agents, buyers agents, buyers advocates, and property developers selling direct. Property managers providing leasing-only services are not captured. Enrolment must be completed by 29 July 2026.
Built on AUSTRAC official guidance · AI-generated · Firm-specific · No legal knowledge required · Ready in 60 seconds
Scope questions
Which real estate professionals are in scope from 1 July 2026?
Source: AUSTRAC — Real estate agents and buyers agents ↗; AML/CTF Act 2006, s.6(5B), Table 6.
In scope
- ●Real estate agents acting for buyer or seller
- ●Buyers agents and buyers advocates
- ●Property developers selling direct to buyers
- ●Agents acting in commercial property transactions
- ●Off-the-plan sales where agent acts for buyer/seller
Not in scope
- ○Property managers (residential leasing only)
- ○Commercial leasing agents (no sale/purchase)
- ○Property valuers
- ○General property advisors not executing transactions
Not legal advice — confirm your specific situation at austrac.gov.au ↗.
Reliance on other reporting entities
Can real estate agents rely on a conveyancer’s CDD?
Yes — but with important conditions. The AML/CTF Act 2006 (s.38) allows a reporting entity to rely on CDD completed by another Australian reporting entity for the same transaction. A real estate agent can rely on a conveyancer’s or lawyer’s identity checks for a buyer or seller.
What you still need when relying on another entity's CDD
You must: (1) document the reliance arrangement before relying on it; (2) confirm the other entity is an Australian reporting entity; (3) keep a record of the reliance arrangement and the CDD outcome. You cannot rely on an overseas entity's checks unless specific conditions under the AML/CTF Rules are met.
Settlement timing — CDD before the deal, not after
CDD must be completed before or at the time of providing the designated service. This is one of the most common mistakes real estate agents make: assuming ID can be collected after the deal is done, after contracts exchange, or at settlement. Where CDD cannot be completed in time, the service must not proceed. Source: AML/CTF Act 2006, s.36.
Source: AML/CTF Act 2006, s.38; AML/CTF Rules 2007, Part 3.
Your obligations
What must real estate agents do by 1 July 2026?
Six steps every in-scope real estate professional must complete. Klyvon generates all required documents automatically.
Confirm your services are designated services
Acting in property purchases or sales is in scope. Leasing and property management only is not. Buyers agents and property developers selling direct are captured.
AML/CTF Act 2006, s.6(5B), Table 6
Enrol with AUSTRAC by 29 July 2026
Register at online.austrac.gov.au. Enrolment opened 31 March 2026. You need your ABN, agency details, and designated services list.
AML/CTF Act 2006, s.76
Appoint a compliance officer and notify AUSTRAC by 30 May 2026
The principal licensee or a senior agent is appropriate. Must be named in writing in your AML/CTF Program.
AML/CTF Act 2006, s.36
Build your AML/CTF Program (Part A + Part B)
Part A covers your ML/TF risk assessment. Part B covers CDD procedures for buyers, sellers, and corporate purchasers.
AML/CTF Act 2006, ss.81–85
Train all agents and staff before 1 July 2026
All agents and support staff involved in property transactions must complete AML/CTF awareness training. Annual refreshers required.
AML/CTF Rules 2007, Part 12
Apply CDD before acting — not after settlement
From 1 July 2026, complete CDD before or at the time of providing the designated service. Acting before CDD is complete is a contravention of the Act.
AML/CTF Act 2006, ss.32–36
What you get
What does Klyvon's AI generate for your real estate practice?
Every document is generated for your specific agency — your name, your compliance officer, your services. Not a generic template. Every document is generated by AI trained on AUSTRAC's official guidance for your sector — then reviewed and owned by you.
AML/CTF Program (Part A + Part B)
Personalised · AI-generatedYour agency-specific compliance program citing the AML/CTF Act 2006. Covers buyer and seller CDD, beneficial ownership checks, cash purchase procedures, reliance provisions, and transaction monitoring.
CDD Templates
Personalised · AI-generatedIdentity verification forms for individual buyers and sellers, corporate purchasers, and trust clients — with enhanced CDD triggers for cash payments, offshore investors, and PEPs.
Staff Training Quiz + Certificate
Personalised · AI-generatedScenario-based training covering AML/CTF red flags for real estate transactions, CDD timing requirements, and how to file an SMR. Generates a dated certificate per agent.
Compliance Officer Letter
Personalised · AI-generatedFormal appointment letter satisfying the written appointment requirement under s.36. Names your designated Compliance Officer and sets out their responsibilities.
AI Suspicious Matter Report Assistant
Personalised · AI-generatedWhen suspicion arises, you have 3 business days to file with AUSTRAC. Klyvon's AI generates a formal 6-section SMR draft from the transaction details you enter — industry-aware language, TTR flag if the amount exceeds $10,000, and your firm's AUSTRAC ID pre-populated. You review and submit.
AI-generated documents are a starting point — reviewed and owned by you. All decisions remain with your firm.
Pricing
How much does AML/CTF compliance cost for a real estate agency?
The Australian government estimates manual compliance preparation costs $23,250 per business using consultants and lawyers. Klyvon generates your complete compliance documents from $99/month + GST — documents ready in under 60 seconds.
Klyvon Compliance Pro — Real Estate Agents
$99/month
- ✓ AML/CTF Program (Part A + Part B)
- ✓ CDD Templates
- ✓ Staff Training Quiz + Certificate
- ✓ Compliance Officer Letter
- ✓ SMR Template + AUSTRAC Enrolment Guide
Cancel before trial ends — no charge · Documents ready in 60 seconds
Common questions
Common questions from real estate agents about AUSTRAC Tranche 2
Are real estate agents required to enrol with AUSTRAC?
Yes, if your agency acts in real property transactions on behalf of buyers or sellers. Acting as a real estate agent in the purchase or sale of real property is a designated service under Table 6 of s.6(5B) of the AML/CTF Act 2006 as amended by the AML/CTF Amendment Act 2024. Enrolment must be completed by 29 July 2026 at online.austrac.gov.au. Source: AML/CTF Act 2006, s.76.
Are buyers agents captured under Tranche 2?
Yes. Buyers agents — also called buyers advocates — act on behalf of purchasers in property transactions. Because they act in a real property transaction, they are providing a designated service under Table 6 of s.6(5B). Buyers agents are often the first professional to interact with a purchaser, making them a natural checkpoint for customer due diligence before any transaction proceeds. Source: AML/CTF Act 2006, s.6(5B), Table 6.
Are property managers captured under Tranche 2?
No. Property management — renting and leasing residential or commercial properties on behalf of landlords — is not a designated service under Tranche 2. Only acting in the purchase or sale of real property triggers AUSTRAC obligations. However, if your agency provides both sales and property management services, the sales side of your business is regulated and you must enrol. Source: AML/CTF Act 2006, s.6(5B), Table 6.
What is reliance and can I rely on a conveyancer's CDD?
Yes. The AML/CTF Act 2006 allows a reporting entity to rely on customer due diligence completed by another reporting entity for the same transaction — this is called reliance. A real estate agent can rely on a conveyancer's or lawyer's CDD checks if: (1) the reliance arrangement is documented; (2) the other entity is an Australian reporting entity; and (3) you retain records of the reliance arrangement and the other entity's CDD outcome. You still need to keep records even when relying on another entity's CDD. Source: AML/CTF Act 2006, s.38.
What CDD do I need to collect on a property buyer?
Before acting for a buyer in a property transaction, you must: (1) verify the buyer's identity — full name, date of birth, and residential address for individuals; (2) for companies, verify the entity's identity and beneficial owners; (3) for trusts, verify the trust and controlling parties. Enhanced CDD is required for PEPs, buyers from high-risk jurisdictions, and transactions with unusual payment arrangements. Source: AML/CTF Act 2006, ss.32–35; AML/CTF Rules 2007, Parts 3–4.
What is a suspicious matter report for a real estate agent?
A Suspicious Matter Report (SMR) must be submitted to AUSTRAC if you know, suspect, or have reasonable grounds to suspect that a transaction is related to money laundering, terrorism financing, or proceeds of crime. For real estate agents, suspicious matters include: cash-intensive purchases, buyers who refuse to provide identification, property purchased at significantly above or below market value, and purchases through opaque corporate or trust structures. SMRs must be submitted within 3 business days of suspicion arising — or 24 hours for terrorism financing. Source: AML/CTF Act 2006, s.41.
Do I need an AML/CTF program for every office in my agency?
No. A single AML/CTF Program can cover all offices of the one reporting entity. If your agency operates as a single legal entity with multiple office locations, one program document covers all offices — provided the program addresses the risks specific to each office's client base and transaction mix. Franchise networks where each franchisee is a separate entity require separate programs per entity. Source: AML/CTF Act 2006, s.84.
What happens if settlement proceeds before CDD is complete?
CDD must be completed before or at the time of providing the designated service — not after. Acting in a property transaction before completing required CDD is a contravention of the AML/CTF Act 2006. This is one of the most common mistakes real estate agents make: assuming CDD can be collected after the deal is done. Where CDD cannot be completed, the service must not proceed. Source: AML/CTF Act 2006, s.36.
Are property developers captured under AUSTRAC Tranche 2?
Yes, if they sell property directly to buyers. A property developer who acts as its own sales agent — selling units or lots directly without using an external agent — is providing a designated service. Developers who use a licensed real estate agent for all sales may rely on the agent's reporting entity status, but should confirm this arrangement with AUSTRAC guidance. Source: AML/CTF Act 2006, s.6(5B), Table 6.
What records do real estate agents need to keep under AML/CTF?
All customer identification records, transaction records, CDD outcomes, SMRs, risk assessments, and AML/CTF Program documents must be retained for a minimum of 7 years from the date the record was made or the transaction completed. Records must be stored securely and retrievable for AUSTRAC examination. Source: AML/CTF Act 2006, ss.112, 162; AML/CTF Rules 2007, Part 10.
Can a principal be the AML/CTF compliance officer?
Yes. There is no requirement for the AML/CTF Compliance Officer to be a dedicated AML specialist. For real estate agencies, the principal licensee or a senior agent is the most common appointment. The Compliance Officer must be named in writing in your AML/CTF Program and be responsible for managing compliance, overseeing staff training, and making AUSTRAC notifications. Source: AML/CTF Act 2006, s.36.
What are the penalties for real estate agencies that don't comply?
Under Part 15 of the AML/CTF Act 2006 (Cth), civil penalties for body corporates can reach $33,000,000 per contravention. Criminal penalties apply for operating without enrolment and for serious non-compliance. AUSTRAC publishes all enforcement actions publicly, creating reputational consequences. Real estate agencies also face potential consequences with state licensing authorities. Source: AML/CTF Act 2006, Part 15; view the AUSTRAC Penalty Register at klyvon.com.au/austrac-penalties.
Can Klyvon help me write a Suspicious Matter Report?
Yes. Klyvon Pro includes an AI Suspicious Matter Report assistant. Enter the transaction date, transaction details, and the suspicious elements you observed. Klyvon's AI generates a formal, AUSTRAC-formatted SMR draft covering all six required sections — reporter obligations under s.41 of the AML/CTF Act 2006, matter details, grounds for suspicion, suspicious indicators, recommended action, and AUSTRAC submission notes. The draft is reviewed by you and submitted directly via AUSTRAC Online. Pro users receive 25 SMR drafts per month.
Build your agency’s AML/CTF program
The 29 July 2026 enrolment deadline is 40 days away.