AUSTRAC Real Estate Town Hall: What You Need to Know About Tranche 2 Reforms
On 19 November 2025, AUSTRAC hosted its first Real Estate Town Hall, a landmark event for property professionals preparing for AML/CTF Tranche 2 reforms. These changes will bring real estate agents, property developers, and conveyancers under Australia’s anti-money laundering framework for the first time.
If you’re in real estate, this is not just a compliance update—it’s a major shift in how you do business. Here’s what was covered and what you need to do now.
AUSTRAC’s Role
AUSTRAC is Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regulator. Its mission is to:
Detect, deter, and disrupt criminal abuse of the financial system.
Collect and analyse financial intelligence to protect Australia from serious crime.
Work with regulated businesses to ensure compliance and reduce risk.
For real estate professionals, AUSTRAC will now oversee your compliance obligations under Tranche 2 reforms.
National Risk Assessment & Real Estate
AUSTRAC’s National Risk Assessment identified real estate as a high-risk sector for money laundering and terrorism financing. Why?
Large transaction values make property attractive for laundering illicit funds.
Complex ownership structures and offshore buyers create opacity.
Cash-heavy deals and informal arrangements increase vulnerability.
This risk profile is a key driver behind Tranche 2 reforms.
Reforms Passing Parliament
The AML/CTF Tranche 2 legislation passed in 2024, marking a significant milestone in Australia’s fight against financial crime.
Effective Date: 1 July 2026
Goal: Align Australia with global standards set by the Financial Action Task Force (FATF).
Impact: Real estate agents, property developers, and conveyancers will become reporting entities under the AML/CTF Act.
Case Study from the Town Hall
AUSTRAC shared a real-world example:
A criminal syndicate laundered 600,000 AUD via a Real Estate Trust Account. This included a 200,000 cash deposit to the buyers agent and 400,000 via domestic transfers to the Real Estate Trust account all referencing the same property.
The lack of due diligence or reporting obligations from the Real Estate Business allowed the scheme to go undetected as the three financial institutions could not see the whole picture.
Lesson: Without robust AML controls, real estate businesses can be exploited for serious crime. Implementing Customer Due Diligence (CDD) and reporting mechanisms is critical to prevent Australia’s financial system from abuse.
Starter Kits & Sector Guidance
To support the industry, AUSTRAC will release in late January 2026:
Starter Kits: Templates for AML/CTF programs, risk assessments, and reporting processes.
Sector Guidance: Practical advice tailored to real estate businesses, including examples of suspicious indicators and compliance checklists.
These resources will help businesses meet obligations without starting from scratch.
AUSTRAC’s Regulatory Expectations
AUSTRAC expects real estate businesses to:
Enrol as a reporting entity from 31 March 2026.
Develop and implement an AML/CTF Program that addresses your specific risks.
Conduct Customer Due Diligence before providing services.
Submit Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs).
Maintain records for at least seven years.
Train staff to recognize red flags and understand compliance obligations.
Compliance Timeline
31 March 2026: Enrolment opens for newly regulated entities.
1 July 2026: Obligations commence.
Town Hall Q&A: Your Questions Answered
Here are some of the most common questions raised during the Town Hall:
Q: How can real estate agents achieve ongoing due diligence?
A: Ongoing due diligence applies when a customer returns after the initial transaction. It involves monitoring subsequent interactions and transactions.
Q: Can we outsource AML/CTF functions to a consultant?
A: Yes, you can engage AML consultants or outsource functions. However, your business remains responsible for compliance.
Q: Do we have to stop business if we submit an SMR?
A: No. You can continue providing services but must manage ML/TF risks appropriately.
Q: What does “enter into an arrangement” mean?
A: It refers to sharing CDD information with another party. You decide who performs screening, but ensure it meets your compliance requirements.
Q: What checks should we do if we don’t manage a trust account?
A: You still need to verify identity and conduct risk checks. Use screening services for PEPs and adverse media.
Q: Do micro businesses or buyers’ agents need to comply?
A: Yes. If you broker a sale or purchase, you are regulated—even if you don’t handle client funds.
Q: Will AUSTRAC provide a portal for sanctions checks?
A: No dedicated portal, but you can use the DAFT Consolidated list & AUSTRAC guidance on sanctions screening.
Why Act Now
Failure to comply can result in:
Civil penalties
Reputational damage
Loss of trust from clients and regulators
Early preparation avoids penalties and ensures smooth compliance.
How AML Advisers Can Help
At AML Advisers, we specialise in helping real estate businesses navigate Tranche 2 reforms. Our services include:
Custom AML/CTF Programs tailored to your risk profile.
Staff training to meet AUSTRAC requirements.
Ongoing compliance support so you stay ahead of regulatory changes.
Don’t wait until July 2026—start preparing now.
📞 Contact AML Advisers today for a free no-obligation consultation and ensure your business is ready for the Tranche 2 reforms.
