AML/CTF rules for real estate agents: what changed on 1 July 2026

On 1 July 2026, Australia's anti-money laundering and counter-terrorism financing laws began to cover real estate. AUSTRAC says the number of businesses it regulates grows that day from around 19,000 to close to 100,000, and its chief executive called the reforms the most significant overhaul of the framework in more than 20 years (AUSTRAC, 31 March 2026).

The rules are written for principals and compliance officers. But an agency's first contact with a buyer or seller usually happens at the front desk: a receptionist, a sales associate, a property manager covering the phones at lunch. This post covers what changed, who is covered, what an agency must have, the enrolment deadline, and what the people taking first details need to know.

What changed on 1 July 2026?

Real estate agents became reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (the AML/CTF Act). The same reforms, often called tranche 2, also brought in legal professionals, accountants, conveyancers and dealers in precious metals and stones (AUSTRAC).

From 1 July, these businesses must comply with the Act's obligations, which AUSTRAC summarises as implementing an AML/CTF program, conducting customer due diligence, reporting suspicious matters and keeping records. Enrolment opened on 31 March 2026, so businesses could enrol ahead of the start date.

Which real estate businesses are covered?

Any business that brokers the sale, purchase or transfer of real estate. In practice that means sellers' agents and buyer's agents, plus property developers who sell house and land packages, off-the-plan apartments or new subdivision blocks without an independent agent (AUSTRAC, Real estate designated services).

Two details matter for agencies:

• Your customer is both parties. When you act for the seller and broker the sale, AUSTRAC treats both the seller and the buyer as your customers, so you have obligations to each.
• Ordinary leasing is outside it. AUSTRAC's definition of real estate excludes leases of 30 years or less. Arranging a standard residential tenancy is not a real estate designated service, so leasing a home on an ordinary tenancy agreement is not covered by these rules.

What must an agency have in place?

AUSTRAC expects four things to be in place from 1 July (AUSTRAC):

• an AML/CTF program that identifies and manages your risks
• an appointed AML/CTF compliance officer
• staff who are trained
• the ability to identify and report suspicious activity when required.

AUSTRAC publishes a real estate program starter kit for agents and buyer's agents. It scales the checks to the customer's risk (AUSTRAC, Step 2). A customer paying more than A$50,000 in physical currency, or paying with cryptocurrency, is high risk and needs enhanced checks such as source of funds and senior manager approval. A purchase over A$1.5 million without a mortgage, or a customer you only ever deal with remotely, counts toward medium risk. Separately, a transaction involving $10,000 or more in physical currency needs a threshold transaction report within 10 business days.

Privacy rules come with it. The OAIC says reporting entities must comply with the Privacy Act 1988 when handling personal information for AML/CTF purposes, including small businesses that are normally exempt, and must limit what they collect to what is reasonably necessary (OAIC).

When is the AUSTRAC enrolment deadline?

29 July 2026 for any business that started providing a designated service on 1 July. The general rule is that you must apply to enrol no later than 28 days after the day you start providing a designated service (AUSTRAC, Enrol with us).

Enrolment is done through AUSTRAC Online. Most real estate agents only need to enrol: registration is a separate process that generally applies to remitters and some virtual asset businesses. Once enrolled, you must update your details within 14 days of any change.

When do you check a buyer's or seller's identity?

Before you start providing the service to the person you act for, and on a later deadline for the other party. AUSTRAC says a seller's agent starts providing the service to the seller when the agreement to broker the sale is signed, and to the buyer when the deal is reasonably expected to proceed, typically when an offer is accepted and the contract is signed (AUSTRAC).

Initial customer due diligence on the seller must be complete before that agreement is signed. Due diligence on the party you don't act for can be delayed, if your program allows it, the delay is essential to avoid interrupting ordinary business and the added risk is low, but must be finished no later than 28 days after exchange of contracts or 3 days before the originally agreed settlement day, whichever comes first (AUSTRAC, Delayed initial CDD). At an auction, where the buyer is only known when the hammer falls, delay can be allowed if there is not enough time before the contract is signed. A buyer's agent works the other way round: due diligence on the buyer comes before the agreement to find a property is signed.

1

Before the agency agreement is signed

Due diligence on the seller

The service to the seller starts when the agreement is signed.

2

Offer accepted, contract signed

The service to the buyer starts

Typically when the deal is reasonably expected to proceed.

3

By 28 days after exchange, or 3 days before settlement

Due diligence on the buyer, if delayed

Whichever comes first. Delay only where your program allows it and the added risk is low.

So the first phone call is not where identity documents get collected. That happens at the point your program sets, which for a seller is before the agency agreement is signed.

What does this mean for whoever answers the phone?

They write down what the caller asked for, pass anything unusual to the compliance officer the same day, and never tell a customer about a suspicion or a report.

Suspicious matter obligations apply as soon as someone asks for a designated service, even if you never end up providing it, because criminals may test several agencies to find a weak one (AUSTRAC, Suspicious matter reports). AUSTRAC lists common indicators, including a customer who:

• wants to stay anonymous, or appears to be acting for someone they won't name
• is evasive or vague when asked for information or reasons
• asks whether you report to AUSTRAC, the Australian Taxation Office or law enforcement.

One indicator on its own may have an innocent explanation. The report is due within 3 business days of forming a suspicion, or 24 hours if it relates to terrorism financing. AUSTRAC expects all customer-facing staff to be trained to recognise suspicious activity and refer it to the right person, so the note about an odd Friday call should not sit in a voicemail until Monday.

The same applies to calls answered after hours. If an assistant such as AgentFront's Phone Assistant takes the calls that ring out, every call is recorded with a transcript and a summary, so your program should say who in the agency reads those summaries and how quickly an unusual request reaches the compliance officer. Our launch post explains what it handles.

This is general information, not legal advice. AUSTRAC's real estate guidance and its program starter kit are the place to check how the rules apply to your agency, and AUSTRAC itself answers questions about a business's own obligations.