What is Tranche 2?
Australia's AML/CTF Act has been in force since 2006, but it originally only covered banks, casinos, remittance dealers and similar financial businesses — these were called "Tranche 1" reporting entities.
After years of review, the government significantly expanded the law in 2024 to cover a much wider range of businesses, including real estate agents, lawyers, accountants, and trust and company service providers. This expansion is called "Tranche 2."
The reason? International bodies like the Financial Action Task Force (FATF) had long identified Australian real estate as a high-risk channel for money laundering — particularly through all-cash purchases and anonymous buyers. Tranche 2 closes that gap.
1 July 2026 is when AML/CTF obligations formally commence for real estate agents. Enrolment with AUSTRAC opened 31 March 2026 and must be completed by 29 July 2026 — but you should enrol and get compliant before 1 July.
Does this apply to my agency?
The law applies to any person or entity that provides a "designated real estate service" in Australia. This covers:
- Selling agents acting for a vendor in a residential or commercial property sale
- Principals and licence holders whose agency conducts property sales
- Corporate agencies and franchise groups through each licensed entity
It does not currently apply to standalone property managers, residential leasing agents, or standalone auctioneers who don't conduct the sale.
Residential property management, leasing, and rental activities are not designated services under the current rules. If your agency does sales and property management, your AML obligations only relate to the sales side.
What does the law require you to do?
There are five main obligations for real estate agents under Tranche 2:
1. Enrol with AUSTRAC
Every agency providing designated real estate services must enrol with AUSTRAC — Australia's financial intelligence regulator. Enrolment is done online at online.austrac.gov.au and takes around 15–20 minutes. The deadline is 29 July 2026, but you should complete it before 1 July.
2. Write an AML/CTF Program
You need a written AML/CTF program that documents how your agency identifies, assesses, and manages money laundering and terrorism financing risk. This must be in place before 1 July 2026. SimpleAML provides free Word templates you can adapt for your agency.
3. Conduct a Risk Assessment
Before writing your program, you need to assess the money laundering risks specific to your agency — the types of properties you sell, your typical clients, your geographic area, and how you accept payment. SimpleAML's free app walks you through this.
4. Verify your clients (CDD)
You must identify and verify the identity of sellers at listing and buyers before exchange (or within 28 days of exchange at auction). This means collecting government-issued photo ID, verifying it's genuine, and keeping records for 7 years. See our CDD guide for full details.
5. Report suspicious matters
If you have reasonable grounds to suspect a transaction involves money laundering or terrorism financing, you must file a Suspicious Matter Report (SMR) with AUSTRAC. Importantly, it is a criminal offence to tip off the person you're reporting.
| Deadline | What you need to do |
|---|---|
| Now → 1 Jul 2026 | Complete your risk assessment, write your AML/CTF program, train your staff |
| 31 Mar → 29 Jul 2026 | Enrol with AUSTRAC (enrolment window) |
| From 1 Jul 2026 | Begin conducting CDD on all new listings and sales |
| ~2029 | First independent AML/CTF program evaluation due |
Why real estate?
Australia has been on FATF's watchlist for years over property-related money laundering. The concerns are well founded: real estate is ideal for "layering" dirty money because property transactions are large, infrequent, and often involve complex ownership structures.
AUSTRAC's own research has identified patterns including all-cash purchases, rapid resales, transactions involving anonymous shell companies, and buyers using third-party funds. The new laws are designed to put real estate agents — who sit at the centre of every property transaction — in a position to detect and report these patterns.
What happens if you don't comply?
Non-compliance carries serious consequences including civil penalties up to $31.3M per contravention, daily penalties for ongoing breaches, criminal liability, and potential referral to state licensing bodies. See our dedicated penalties guide for full details.
Ready to get compliant?
SimpleAML's free app walks you through every step — risk assessment, AML program upload, staff vetting, AUSTRAC enrolment, and your listing register. No subscription, no cost.
Open the free app → Download free templates