Frequently Asked Questions

Tranche 2 refers to Australia’s upcoming expansion of AML/CTF laws. It will impose mandatory Anti-Money Laundering obligations on real estate professionals, lawyers, and accountants – sectors currently unregulated under AML laws. Some people think Know Your Customer (KYC) is AML which is incorrect. The best way to describe AML is its a way to check who your clients are, where their money comes from, and reporting anything suspicious, so you’re not unknowingly helping someone clean dirty money.

Under tranche 2 real estate agents must: 

1. Enrol and register with AUSTRAC

2. Develop and maintain an AML/CTF program

3. Appoint a responsible Compliance Officer

4. Verify buyer/seller identity (KYC)/ Customer Due Diligence (CDD)

5. Report suspicious and large cash transactions

6. Make and keep records for 7 years

7. Undergo independent audits every 3 years

October 2025, core guidelines are expected to be published by AUSTRAC.

 Here’s a breakdown of how and why the process changes:

1. Client Onboarding and Verification (less than 60 seconds wiht our tech)

Before: Basic collection of client details and property information.
After: Agents must verify the identity of the seller and any beneficial owners.

Collect supporting documents like government IDs, proof of address, corporate ownership documents (if applicable).
Screen clients against PEP lists, sanctions lists, and adverse media.

Impact: Longer onboarding time; need for more documentation before listing a property.

2. Source of Funds Checks

Before: Minimal or informal verification of funds.
After: Agents may need to verify the source of the seller’s funds to ensure they are not illicit.

For high-value or cash-heavy transactions, detailed bank statements or proof of income may be required.

Impact: More detailed questioning and documentation; potential delays if clients cannot provide proof immediately.

3. Risk Assessment of the Property Transaction

Before: Focus on market value, location, and buyer interest.
After: Each listing may undergo a risk assessment to determine if enhanced due diligence is needed.

Factors include: unusual pricing, offshore entities involved, or complex ownership structures.

Impact: Agents may need to flag certain properties for compliance review before marketing.

4. Documentation and Recordkeeping ( we store consumables for you)

Before: Standard property listing forms and agreements.
After: Maintain comprehensive records of client verification, funds source, and risk assessment.

Documents may need to be stored for 7 years.

Impact: Increased administrative workload.

5. Transaction Monitoring During the Sale

Before: Focus on matching buyers and sellers.
After: Agents must monitor the transaction for suspicious activity.

Escalate red flags to the firm’s AML Compliance Officer before closing.

Impact: Agents become active monitors, not just intermediaries.

6. Training and Awareness

Before: General legal knowledge and ethics.
After: Agents need AML-specific training, including identifying red flags and proper reporting procedures.

Impact: Mandatory training sessions; ongoing updates as regulations evolve.

October 2025,core guidelines are expected to be published by AUSTRAC.

December 2025, Sector specific guidance released. 

1 July 2026, AML/CTF regulations for real estate professionals in Australia will come into effect.

By 31 March 2026, Businesses must register with AUSTRAC. This registration is a prerequisite for meeting the upcoming obligations.

Whether you’re a single office or part of a national network, our platform and local team scale with your business and provide expert help when you need it.

Here are some but not limited to things agents should be redy to keep an eye on.

• High-Value Transactions, Real estate deals often involve large sums of money
• Use of Complex Ownership Structures
• Cash and Unusual Payment Methods
• Over- or Under-Valued Transactions
• Politically Exposed Persons (PEPs) and High-Risk Clients
• Rapid Buy-and-Sell Activity
• Lack of Transparency in Funding Sources
• Overseas Transactions
• Use of Third Parties

Real estate is a high-risk sector for money laundering due to:

• Large transactions that can obscure illicit funds.
• Use of corporate structures, trusts, or offshore entities.
• Opportunities to launder proceeds through property purchases or rentals.
  AML compliance helps prevent legal, reputational, and financial risks.

• Regulatory fines and sanctions for the company.

• Personal liability for staff or management in severe cases.

• Damage to reputation and potential legal action.

We’re here to help! we track a lot of information automatically to help identify Red flags. Some can include:

• Unusually complex ownership structures.

• Frequent buying and selling without clear business purpose.

• Clients reluctant to provide personal or financial information.

• Transactions significantly above market value.

Our partner Equifax helps verify and identify whats required to make sure your agency is compliant with the upcoming AML regulations. 

• Collect identification documents (passport, national ID).

• Verify the client’s address and contact information.

• Perform background checks on companies or trusts involved.

• Maintain proper documentation to comply with audit requirements.

• Store records for 7 years