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 the AML/CTF Act 2006 as amended by the AML/CTF Amendment Act 2024. Enrolment had a transitional deadline of 29 July 2026, which has passed at online.austrac.gov.au.

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. 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.

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.

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.

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.

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.

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.

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.

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.

What records do real estate agents need to keep under AML/CTF?

Different AML/CTF record categories have different retention rules and statutory triggers. Program records, CDD records, transaction records, reporting records and training or program-compliance records must be retained for their applicable statutory periods. Records must be stored securely and retrievable for AUSTRAC examination.

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.

What are the penalties for real estate agencies that don't comply?

Under the AML/CTF Act 2006 (Cth), civil penalties for body corporates can reach up to $36,400,000 per contravention (based on the penalty unit rate of $364, effective 1 July 2026). 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.

Does Klyvon include sanctions screening?

Targeted financial sanctions screening is now part of your AML/CTF program obligation under the AML/CTF Rules 2025 — not a separate exercise. Klyvon's generated program includes the required policy controls for targeted financial sanctions. You will still need to screen clients against the DFAT Consolidated List as part of your CDD workflow. Klyvon does not run live screening checks, but your program documents exactly when and how to do it.

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 your agency. The independent evaluation must assess: your ML/TF risk assessment against the Act and Rules, the design of your AML/CTF policies, your actual compliance with those policies, and whether you're appropriately identifying, assessing, and mitigating ML/TF risk. Findings go in a written report to your governing body or a responsible senior manager.

I started providing a designated service after 1 July 2026 — do I still need to enrol by 29 July 2026?

No. The 29 July 2026 date only ever applied to businesses that were already providing a designated service on 1 July 2026, and that date has passed. If you started after 1 July, you have 28 days from the date you started to enrol with AUSTRAC — this rule applies on an ongoing basis, not just around the Tranche 2 rollout. Full explanation and worked examples: https://www.klyvon.com.au/austrac-enrolment-28-day-rule.

Updated August 2026

Field Guide · Real Estate & Buyers Agents

AUSTRAC AML/CTF requirements for real estate agents

Waiting until settlement week to ask a buyer for ID is the single most common failure AUSTRAC's real estate guidance flags. By then, the deal is already done.

Build your agency's AML/CTF program →See the CDD deadline

7
Steps to compliance: 29 Jul
Enrolment deadline (passed): 3 days
SMR lodgement: Varies
Retention periods

Real-estate businesses may be regulated when they act on behalf of buyers or sellers in the purchase or sale of real property, because that is a designated service. AML/CTF obligations have been in effect since 1 July 2026. Customer due diligence must be completed before or at the time the designated service is provided; on this page, that means completing CDD by exchange rather than waiting until settlement.

⚠ Enrolment deadline passed 29 July 2026 · Agencies not yet enrolled are exposed to enforcement nowaustrac.gov.au ↗

In this guide

CDD timing against a transaction Who's captured, who isn't What agents must do, step by step What Klyvon generates for you Frequently asked questions Get compliant with Klyvon

I. The Deadline Nobody Schedules

Can CDD be finished after contracts exchange?

No. And the reason agents get this wrong is that nothing about a normal transaction forces the question until it's too late to fix.

DD must be completed before or at the time of providing the designated service — not after. That single line covers the most common mistake AUSTRAC’s real estate guidance identifies: agents assuming identity can be collected once a deal feels certain, during the settlement countdown, or worse, at settlement itself. By then, the service has already been provided. Where CDD can’t be completed in time, the transaction must not proceed — not paused, not backfilled, stopped.

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.

“Acting in a property transaction before completing required CDD is a contravention — assuming ID can be collected after the deal is done is one of the most common mistakes real estate agents make.”
— AML/CTF Act 2006, s.28

II. Who's Actually Captured

Which real estate professionals have been in scope since 1 July 2026?

Sales are regulated. Leasing and property management, generally, are not.

In scope

Real estate agents acting for buyer or seller
Buyers agents and buyers advocates
Property developers selling direct to buyers (scope depends on the specific arrangement)
Agents acting in commercial property transactions
Off-the-plan sales where an agent acts for buyer or 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 ↗.

Property-transaction red flags

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.

“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

III. What Agents Must Do

Seven steps every in-scope agency must have completed

Klyvon generates the documents this list requires automatically — enrolment and training are the two steps that stay yours to action.

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 — though whether a particular developer model is in scope depends on the specific arrangement; seek legal advice if unsure.

Enrol with AUSTRAC now if not enrolled

Register at online.austrac.gov.au. Enrolment opened 31 March 2026. You need your ABN, agency details, and designated services list.

Appoint a compliance officer and notify AUSTRAC

The principal licensee or a senior agent is appropriate. Must be named in writing in your AML/CTF Program and notified to AUSTRAC within 14 days of the appointment.

Build your AML/CTF Program

Cover your ML/TF risk assessment and CDD procedures for buyers, sellers, and corporate purchasers.

Train relevant personnel

Provide initial and ongoing AML/CTF training for personnel performing relevant functions, appropriate to their functions, relevant ML/TF risks and responsibilities.

Apply CDD before acting — not after settlement

Since 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.

Schedule your independent evaluation

At least once every 3 years (more often if your agency's size or complexity warrants it), arrange an independent evaluation covering your risk assessment, policy design, actual compliance, and risk mitigation effectiveness.

Reliance note

A real estate agent can rely on a conveyancer’s or lawyer’s CDD for the same transaction — but the reliance arrangement must be documented, the other entity must be an Australian reporting entity, and you must keep records 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.

IV. What You Get

Five documents, built for your specific agency

Not a generic template — your name, your compliance officer, your services, generated for review.

AML/CTF Program

Agency-specific compliance program covering buyer and seller CDD, beneficial ownership checks, cash purchase procedures, reliance provisions, and transaction monitoring.

CDD Templates

Identity verification forms for individual buyers and sellers, corporate purchasers, and trust clients — with enhanced CDD triggers for cash payments, offshore investors, and PEPs.

Role-Based Staff Training + Certificate

Mandatory now that obligations are in effect — interactive modules tailored to each agent's role, with real-estate scenarios covering red flags and CDD timing. Dated certificate per agent, retained for the applicable statutory period.

Compliance Officer Letter

A record of the agency's compliance-officer designation. The agency remains responsible for ensuring the designated individual meets the applicable requirements.

SMR Assistant

When suspicion arises, you have 3 business days to file. Klyvon prepares an SMR draft from the information entered for review before submission through AUSTRAC Online.

V. Reference

Common questions from real estate agents

VI. How Klyvon Helps

Compliance doesn’t end at enrolment — Klyvon runs alongside your agency

Your program, risk assessment, and CDD templates are generated for review. Then Klyvon keeps working — tracking staff training and review dates, drafting SMRs, and answering the questions that come up between reviews.

Risk assessment, built to your agency

A documented ML/TF risk assessment across buyer and seller transactions, delivery channels, and payment types — not a generic template with your agency's name on it.

Mandatory training, by role — not a generic quiz

Interactive modules assigned by staff role, with real-estate scenarios. Completion certificates generated automatically and retained for the applicable statutory period — required now that obligations are in effect, not optional.

SMR drafting when suspicion arises

Prepare an SMR draft from the information entered for review before submission through AUSTRAC Online.

Answers instead of pointing you at a PDF

Ask a plain question about a real transaction — a buyer refusing ID days before exchange, an offshore purchaser structure.

Get started free →

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Primary sources

AUSTRAC — Tranche 2 reform guidance

Last updated 20 August 2026 · Klyvon Compliance Team

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