Navigating AML compliance for real estate: Tranche 2 explained
Under Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime, real estate agents and agencies will be subject to new rules & requirements when it comes to identifying buyers and sellers.
These changes fall under what’s known as ‘Tranche 2’. Tranche 2 and the expansion of these AML/CTF laws will impact all real estate professionals, including buyer’s agents and even some property developers. If you assist clients with buying or selling property, you will likely be within the regulatory scope.
What are the new AUSTRAC real estate AML obligations?
Tranche 2 introduces several new AML compliance, specifically for real estate agents. While final guidance is still being finalised, here’s what is currently expected:
| Obligation | What it means |
| AUSTRAC enrolment | Register your business with AUSTRAC by July 2026. |
| AML/CTF program | Develop a written, risk-based compliance program and regularly review and audit this. |
| KYC (Know Your Customer) | Conduct checks to verify the identity of buyers and sellers that you deal with on property transactions. |
| Ongoing due diligence | Regularly monitor client activity and reassess their risk. Records need to be maintained for at least seven years. |
| Reporting suspicious matters | Report activity that seems unusual or suspicious to AUSTRAC |
| Staff training | Make sure your team understands red flags and reporting steps |
Non-compliance with AML/CTF obligations can lead to serious consequences, including fines, legal action and public enforcement by AUSTRAC. Even unintentional breaches can result in reputational damage or the loss of key referral relationships. Real estate businesses that ignore Tranche 2 risk being caught unprepared when the rules take effect in 2026.
Why is real estate in focus?
Real estate is considered a high-risk for money laundering because of large transactions, cash payments and involvement of multiple parties. Tranche 2 aims to close loopholes and align Australia with global AML/CTF standards.
Remember: You're not being asked to investigate potential financial crimes. The onus is on you to simply report any suspicious matters and leave the rest to AUSTRAC.
How does easyAML help real estate professionals with AML compliance?
At easyAML, we undesrstand that you're busy, always on the move and focused on getting deals done. You don’t want to be wading through compliance documents. We designed easyAML as a comprehensive, user-friendly platform specifically for businesses like yours.
1. Easy onboarding
- Real estate-specific AML/CTF templates
- Guided, AUSTRAC-aligned risk assessment setup
- Local support whenever you need it
2. Smart, fast identity checks
- Digital KYC for buyers and sellers
- Biometric checks, facial matching & secure ID capture
- Address verification and watchlist screening
3. Ongoing compliance tools
- Smart risk scoring to help guide you and your team
- Audit-ready reporting, aligned with AUSTRAC’s requirements
- Ongoing updates to ensure you remain compliant as rules change
Life has been much easier for both me and my clients. Verifying is quicker, even in tricky cases. Support is always responsive, and the service is second to none.
Salib Settlements
FAQs: Real Estate AML
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Do real estate agents need to comply with AML/CTF laws?
Yes. From 1 July 2026, real estate agents involved in property transactions will need to comply with AML/CTF obligations. This includes identity checks on buyers and sellers, risk assessments and record-keeping. Tranche 2 captures real estate as a high-risk sector under AUSTRAC's regulatory expansion.
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What kinds of transactions are covered under the real estate AML rules?
AML obligations apply when you assist with buying, selling or transferring real estate on behalf of a client. This includes acting as an agent, facilitating settlement, or managing funds — even direct sales by developers may trigger compliance requirements under Tranche 2.
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Do property managers need to comply with AML/CTF laws?
Possibly. If your property management services include handling rental funds, bond payments, or other transactions, you may fall under AUSTRAC’s designated services. Review your service offerings carefully and consult AUSTRAC’s upcoming guidance to see if your business is captured. Not sure if you’re affected? Talk with us to see if you'll be impacted.
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Is digital verification required for real estate AML compliance?
Digital verification isn’t mandatory, but it’s strongly recommended. Under Tranche 2, you must verify each client’s identity before providing services. Digital verification streamlines this process, reduces manual errors and ensures your checks meet AUSTRAC standards, especially for remote clients or busy agencies without in-house compliance staff.
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How do real estate agents perform KYC checks?
KYC (Know Your Customer) checks involve verifying a client’s identity before a transaction begins. This includes ID verification, checking beneficial ownership for companies and ongoing risk assessments. AML software can automate this process and help your agency stay compliant without adding operational burden.
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What happens if we don’t comply with AML regulations?
Non-compliance can result in fines, enforcement notices and AUSTRAC publicly listing your agency as non-compliant. It may damage your reputation and result in lost trust from banks, clients, and partners. Compliance protects your agency and shows that you're operating to professional standards.
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Is AML software necessary for small real estate offices?
Yes. AML software simplifies the entire compliance process, from verifying clients to managing risk and reporting to AUSTRAC. For small and medium agencies without in-house staff who specialise in compliance, a solution like easyAML helps you meet every requirement without added complexity or legal costs.
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How can I prepare my real estate agency for Tranche 2?
Start by understanding whether your services fall under the new rules, then enrol with AUSTRAC, create an AML/CTF program and implement client due diligence processes. Tools like easyAML make it easier to get started and stay compliant with support tailored for the property industry.
Stay prepared, without the panic
Remember, you don’t need to panic. You just need a plan and the right support. Which is what we’re here for!
Join our AML readiness list for simple updates, tailored advice and real estate-specific tools to help you prepare with confidence.