Tranche 2 AML/CTF Reforms: What Real Estate Agents Need to Know

The Federal Government is moving ahead with Tranche 2 reforms to Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006, expanding the regime to include new “gatekeeper” professions such as real estate agents, lawyers, accountants, and trust-service providers.

These reforms are scheduled to take effect from 1 July 2026 and will require real estate professionals to conduct customer due diligence, report suspicious transactions, and combat financial crime.

What is covered under “real estate services”?

Under the legislation, a designated service includes:

  • Brokering the sale, purchase, or transfer of real estate on behalf of a client (for example, acting as a sales agent or buyers’ agent).
  • Property developers selling real estate directly to purchasers.
  • Assisting in the planning or execution of a real estate sale or transfer (such as settlement or transfer of title).

In other words, if your business is involved in the sale or purchase of property, you’ll likely fall within the new Tranche 2 regime.

Activities that do not involve the sale or transfer of ownership—such as property management, residential leasing, and holiday letting—are expected to remain outside the scope of the reforms.

What this means for real estate agents

Once the reforms commence, real estate agencies that provide designated services will become “reporting entities” under the AML/CTF Act and will be required to:

  1. Enrol with AUSTRAC. You must enrol your business with AUSTRAC within 28 days of providing a regulated service. Enrolment for Tranche 2 entities will open on 31 March 2026. Enrol or register here.
  2. Implement an AML/CTF Program that sets out how you will identify, mitigate, and manage money-laundering and terrorism-financing risks.
  3. Perform customer due diligence (KYC) on vendors and buyers before providing services.
  4. Report suspicious matters and certain transactions to AUSTRAC.
  5. Maintain records of identification, transactions, and compliance activities.

Failure to comply could lead to significant penalties and regulatory action.

What about management rights operators?

For those in the management rights industry, most activities involve property management and short-term or permanent letting. These services do not involve property sales or transfers, and therefore are unlikely to be captured under Tranche 2.

However, if you are a manager who also acts as a selling agent (for example, selling units in your complex or referring buyers for commission), those specific activities may bring you within the new regime.

What you should do now

Although the start date is still a while away, preparation should begin early. We recommend that real estate businesses:

  • Review your service offerings to confirm whether you are involved in any “designated services” under the reforms.
  • Assess your existing processes for verifying clients’ identities and recording transactions.
  • Start building an AML/CTF Program appropriate to your size and risk profile.
  • Train your team on identifying and reporting suspicious activity.
  • Stay informed as the final legislation and AUSTRAC guidance are released.
  • Enrol or register with AUSTRAC (enrolment for Tranche 2 entities opens on 31 March 2026).

For real estate agents who sell property, AML/CTF obligations are coming and compliance will soon become a normal part of doing business. While the new rules are still being finalised, early awareness and preparation will make the transition far smoother.

For more information, see AUSTRAC’s summary of obligations for the reforms: read the AUSTRAC guidance.

Disclaimer: This article contains general information only. Regrettably, no responsibility can be accepted for errors, omissions or possible misleading statements or for any action taken as a result of any material in this guide. It is not designed to be a substitute for professional advice, as such a brief guide cannot hope to cover all circumstances and conditions applying to the law as it relates to these items.

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Chantel Du Plessis, Senior Client Manager at Holmans Chartered Accountants, smiling in professional headshot

Chantel du Plessis, CPA

As a Senior Client Manager at Holmans, Chantel Du Plessis has spent several years working alongside clients in the Management Rights industry. With strong industry knowledge and a genuine passion for helping businesses succeed, she combines technical expertise with practical insight to support clients through every stage of ownership, from purchase and setup, to ongoing management, compliance, and eventual sale.

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