Obligations are in effect·Enrolment deadline: 29 July 2026—21 days remaining
AML/CTF Compliance · Real Estate Agents Australia · 5 min read · Klyvon Compliance Team
AML compliance for real estate agents in Australia — AUSTRAC Tranche 2
Since 1 July 2026, Australian real estate agents acting on property purchase or sale transactions are AUSTRAC reporting entities under the AML/CTF Amendment Act 2024 — these obligations are now in effect. This guide covers who is captured, what the CDD requirements are for property transactions, and how to comply, including the 29 July 2026 enrolment deadline still ahead. For the full industry guide see /real-estate.
Written by the Klyvon Compliance Team · Melbourne, Australia · General guidance only, not legal advice
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1 Jul 2026
Obligations commenced
All requirements are now live
Who is captured — and who is not
Captured (reporting entity)
✓ Vendors' agents acting on property sales
✓ Buyers agents acting on property purchases
✓ Buyers advocates
✓ Property developers selling directly to buyers (in some circumstances)
✓ Agents handling both residential and commercial transactions
NOT captured
✗ Residential property managers (leasing only)
✗ Rent collection and maintenance services
✗ Strata managers
✗ Property valuers
✗ Mortgage brokers (already Tranche 1)
✗ Real estate auctioneers acting on behalf of agents
Property transaction CDD — what you must verify
For every property purchase or sale transaction, you must conduct customer due diligence before acting on behalf of the client. The specific requirements:
Individual buyers and sellers
Full name, date of birth, and residential address. Verify using reliable, independent source documents (government-issued photo ID + secondary document).
Company buyers and sellers
Verify the company via ASIC records. Identify and verify all beneficial owners — individuals with more than 25% ownership or effective control.
Trust structures
Identify the trustee, settlor, and all beneficiaries. Verify the trust deed where possible. Enhanced due diligence for discretionary trusts with multiple beneficiary classes.
Source of funds
For high-value transactions or where the source of funds is unclear or inconsistent with the client's profile, document the source of purchase funds.
Politically exposed persons (PEPs)
Apply enhanced due diligence to any buyer or seller who is a current or former senior government official or their immediate family member.
Why real estate is a high-priority AUSTRAC target
Australian residential real estate has long been identified by AUSTRAC and the Australian Criminal Intelligence Commission (ACIC) as a high-risk sector for money laundering. The combination of high transaction values, complex ownership structures, and international buyers creates significant ML/TF risk. AUSTRAC's Tranche 2 real estate guidance specifically highlights: all-cash purchases, transactions involving offshore entities or funds, rapid buy-sell cycles, and transactions significantly below or above market value as red flags requiring enhanced scrutiny.
Frequently asked questions
Do real estate agents need to register with AUSTRAC?
Yes, if your real estate agency acts on property purchase or sale transactions. This includes vendors' agents, buyers agents, and buyers advocates acting on purchases. Acting on a transaction means acting as an agent in the execution of a purchase or sale — not merely advertising a property or managing a rental. Residential property managers who only provide leasing, rent collection, and maintenance services and do not act on purchase or sale transactions are generally not reporting entities.
What AML program does a real estate agency need?
Real estate agencies must implement an AML/CTF program covering a risk management framework (including ML/TF risk assessment, compliance officer, transaction monitoring, staff training) and customer due diligence procedures (for buyers, sellers, and beneficial owners). AUSTRAC no longer requires these to be structured as separate labelled 'Part A'/'Part B' sections — you can organise your program as suits your business. The program must specifically address property transaction risk factors including payment source verification, international buyers, and high-value transactions.
How much does AUSTRAC compliance cost for real estate agents?
The government's Regulation Impact Statement estimated significant ongoing compliance costs for small businesses — covering staff time, external advice, and software. Klyvon is designed to reduce that cost substantially. Boutique AML consultants charge $5,000–$15,000 for real estate agency programs. Klyvon is purpose-built for Australian real estate agents — it generates a firm-specific AML/CTF program in one session from $299/month.
What happens if a real estate agent doesn't comply now that obligations are in effect?
Operating as a reporting entity without an AML/CTF program and CDD procedures, now that obligations commenced 1 July 2026, is a contravention of the AML/CTF Act 2006. Civil penalties can reach $33,000,000 per contravention for bodies corporate (real estate agencies operating as companies) (based on the current penalty unit rate of $330; due to re-index 1 July 2026 pending official publication). Non-enrolment after 29 July 2026 attracts daily penalties of up to $19,800. In addition to AUSTRAC penalties, estate agents may face consequences under state real estate licensing frameworks.
Can real estate agents use AI to generate their AML program?
Yes. Klyvon is purpose-built for Australian real estate agents — it generates a firm-specific AML/CTF program in one session from $299/month. The AI is prompted with AUSTRAC's published Real Estate Starter Kit and sector guidance as context. The generated program covers your risk framework and CDD procedures specific to property transactions, including verification of buyers, sellers, and beneficial owners of corporate clients. The program must be reviewed and adopted by your compliance officer before implementation.
How often must a real estate agency get an independent evaluation of its AML/CTF program?
At least once every 3 years, and more often if appropriate to the size and complexity of the agency. This is a separate, mandatory requirement under the AML/CTF Act — distinct from the agency's annual internal program review. The independent evaluation must assess the agency's ML/TF risk assessment, the design of its AML/CTF policies, its actual compliance with those policies, and whether it's appropriately identifying, assessing, and mitigating ML/TF risk. Findings go in a written report to the agency's governing body or a responsible senior manager.
Built for Australian real estate agents
Klyvon generates your complete AML/CTF program in one session. From $299/month.
General guidance only · Not legal advice