Obligations are in effect·Enrolment deadline: 29 July 2026—21 days remaining
AML/CTF Compliance · Real Estate Agents & Buyers Agents
AUSTRAC Tranche 2 Compliance for Real Estate Agents & Buyers Agents
Since 1 July 2026, real estate professionals acting on property transactions in Australia are in scope under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) as amended by the AML/CTF Amendment Act 2024. This includes real estate agents, buyers agents, buyers advocates, and property developers selling direct (whether scope applies to a particular developer model depends on the specific arrangement — seek legal advice if unsure). Property managers providing leasing-only services are not captured. Enrolment must be completed by 29 July 2026.
Built on AUSTRAC official guidance · Built to current law · Firm-specific · No legal knowledge required · Ready in one session
Scope questions
Which real estate professionals have been in scope since 1 July 2026?
In scope
- ●Real estate agents acting for buyer or seller
- ●Buyers agents and buyers advocates
- ●Property developers selling direct to buyers (scope depends on specific arrangement — seek legal advice if unsure)
- ●Agents acting in commercial property transactions
- ●Off-the-plan sales where agent acts for buyer/seller
Not in scope
- ○Property managers (residential leasing only)
- ○Commercial leasing agents (no sale/purchase)
- ○Property valuers
- ○General property advisors not executing transactions
Not legal advice — confirm your specific situation at austrac.gov.au ↗.
Reliance on other reporting entities
Can real estate agents rely on a conveyancer’s CDD?
Yes — but with important conditions. The AML/CTF Act 2006 allows a reporting entity to rely on CDD completed by another Australian reporting entity for the same transaction. A real estate agent can rely on a conveyancer’s or lawyer’s identity checks for a buyer or seller.
What you still need when relying on another entity's CDD
You must: (1) document the reliance arrangement before relying on it; (2) confirm the other entity is an Australian reporting entity; (3) keep a record of the reliance arrangement and the CDD outcome. You cannot rely on an overseas entity's checks unless specific conditions under the AML/CTF Rules are met.
Settlement timing — CDD before the deal, not after
CDD must be completed before or at the time of providing the designated service. This is one of the most common mistakes real estate agents make: assuming ID can be collected after the deal is done, after contracts exchange, or at settlement. Where CDD cannot be completed in time, the service must not proceed.
Your obligations
What must real estate agents do now that Tranche 2 is in effect?
Seven steps every in-scope real estate professional must complete. Klyvon generates all required documents automatically.
Confirm your services are designated services
Acting in property purchases or sales is in scope. Leasing and property management only is not. Buyers agents and property developers selling direct are captured — though whether a particular developer model is in scope depends on the specific arrangement; seek legal advice if unsure.
Enrol with AUSTRAC by 29 July 2026
Register at online.austrac.gov.au. Enrolment opened 31 March 2026. You need your ABN, agency details, and designated services list.
Appoint a compliance officer and notify AUSTRAC by 29 July 2026
The principal licensee or a senior agent is appropriate. Must be named in writing in your AML/CTF Program.
Build your AML/CTF Program
Cover your ML/TF risk assessment and CDD procedures for buyers, sellers, and corporate purchasers.
Train all agents and staff
All agents and support staff involved in property transactions must complete AML/CTF awareness training. Annual refreshers required.
Apply CDD before acting — not after settlement
Since 1 July 2026, complete CDD before or at the time of providing the designated service. Acting before CDD is complete is a contravention of the Act.
Schedule your independent evaluation
At least once every 3 years (more often if your agency's size or complexity warrants it), arrange an independent evaluation covering your risk assessment, policy design, actual compliance, and risk mitigation effectiveness. A written report goes to your governing body or responsible senior manager. Distinct from your annual internal review.
What you get
What does Klyvon build for your real estate practice?
Every document is generated for your specific agency — your name, your compliance officer, your services. Not a generic template. Every document is built to current law using AUSTRAC's official guidance for your sector as context — then reviewed and owned by you.
AML/CTF Program
Personalised · Built to current lawYour agency-specific compliance program citing the AML/CTF Act 2006. Covers buyer and seller CDD, beneficial ownership checks, cash purchase procedures, reliance provisions, and transaction monitoring.
CDD Templates
Personalised · Built to current lawIdentity verification forms for individual buyers and sellers, corporate purchasers, and trust clients — with enhanced CDD triggers for cash payments, offshore investors, and PEPs.
Staff Training Quiz + Certificate
Personalised · Built to current lawScenario-based training covering AML/CTF red flags for real estate transactions, CDD timing requirements, and how to file an SMR. Generates a dated certificate per agent.
Compliance Officer Letter
Personalised · Built to current lawFormal appointment letter satisfying the written appointment requirement under the AML/CTF Act 2006. Names your designated Compliance Officer and sets out their responsibilities.
Suspicious Matter Report Assistant
Personalised · Built to current lawWhen suspicion arises, you have 3 business days to file with AUSTRAC. Klyvon drafts a formal 6-section SMR from the transaction details you enter — industry-aware language, TTR flag if the amount exceeds $10,000, and your firm's AUSTRAC ID pre-populated. You review and submit.
Documents built to current law are a starting point — reviewed and owned by you. All decisions remain with your firm.
Pricing
How much does AML/CTF compliance cost for a real estate agency?
Compliance consultants charge $8,000–$50,000 to build your program. Klyvon generates your complete compliance documents from $299/month — documents ready in one session.
Why Klyvon?
$8,000–$50,000 to build your program
Custom program development
From $299/month — built to current law in one session
Month-to-month · cancel anytime
Klyvon Essential — Real Estate Agents
$299/month
- ✓ AML/CTF Program (risk framework and CDD procedures)
- ✓ CDD Templates
- ✓ Staff Training Quiz + Certificate
- ✓ Compliance Officer Letter
- ✓ SMR Template + AUSTRAC Enrolment Guide
Month-to-month · cancel anytime · Documents ready in one session
Common questions
Common questions from real estate agents about AUSTRAC Tranche 2
Are real estate agents required to enrol with AUSTRAC?
Yes, if your agency acts in real property transactions on behalf of buyers or sellers. Acting as a real estate agent in the purchase or sale of real property is a designated service under the AML/CTF Act 2006 as amended by the AML/CTF Amendment Act 2024. Enrolment must be completed by 29 July 2026 at online.austrac.gov.au.
Are buyers agents captured under Tranche 2?
Yes. Buyers agents — also called buyers advocates — act on behalf of purchasers in property transactions. Because they act in a real property transaction, they are providing a designated service. Buyers agents are often the first professional to interact with a purchaser, making them a natural checkpoint for customer due diligence before any transaction proceeds.
Are property managers captured under Tranche 2?
No. Property management — renting and leasing residential or commercial properties on behalf of landlords — is not a designated service under Tranche 2. Only acting in the purchase or sale of real property triggers AUSTRAC obligations. However, if your agency provides both sales and property management services, the sales side of your business is regulated and you must enrol.
What is reliance and can I rely on a conveyancer's CDD?
Yes. The AML/CTF Act 2006 allows a reporting entity to rely on customer due diligence completed by another reporting entity for the same transaction — this is called reliance. A real estate agent can rely on a conveyancer's or lawyer's CDD checks if: (1) the reliance arrangement is documented; (2) the other entity is an Australian reporting entity; and (3) you retain records of the reliance arrangement and the other entity's CDD outcome. You still need to keep records even when relying on another entity's CDD.
What CDD do I need to collect on a property buyer?
Before acting for a buyer in a property transaction, you must: (1) verify the buyer's identity — full name, date of birth, and residential address for individuals; (2) for companies, verify the entity's identity and beneficial owners; (3) for trusts, verify the trust and controlling parties. Enhanced CDD is required for PEPs, buyers from high-risk jurisdictions, and transactions with unusual payment arrangements.
What is a suspicious matter report for a real estate agent?
A Suspicious Matter Report (SMR) must be submitted to AUSTRAC if you know, suspect, or have reasonable grounds to suspect that a transaction is related to money laundering, terrorism financing, or proceeds of crime. For real estate agents, suspicious matters include: cash-intensive purchases, buyers who refuse to provide identification, property purchased at significantly above or below market value, and purchases through opaque corporate or trust structures. SMRs must be submitted within 3 business days of suspicion arising — or 24 hours for terrorism financing.
Do I need an AML/CTF program for every office in my agency?
No. A single AML/CTF Program can cover all offices of the one reporting entity. If your agency operates as a single legal entity with multiple office locations, one program document covers all offices — provided the program addresses the risks specific to each office's client base and transaction mix. Franchise networks where each franchisee is a separate entity require separate programs per entity.
What happens if settlement proceeds before CDD is complete?
CDD must be completed before or at the time of providing the designated service — not after. Acting in a property transaction before completing required CDD is a contravention of the AML/CTF Act 2006. This is one of the most common mistakes real estate agents make: assuming CDD can be collected after the deal is done. Where CDD cannot be completed, the service must not proceed.
Are property developers captured under AUSTRAC Tranche 2?
Yes, if they sell property directly to buyers. A property developer who acts as its own sales agent — selling units or lots directly without using an external agent — is providing a designated service. Developers who use a licensed real estate agent for all sales may rely on the agent's reporting entity status, but should confirm this arrangement with AUSTRAC guidance.
What records do real estate agents need to keep under AML/CTF?
All customer identification records, transaction records, CDD outcomes, SMRs, risk assessments, and AML/CTF Program documents must be retained for a minimum of 7 years from the date the record was made or the transaction completed. Records must be stored securely and retrievable for AUSTRAC examination.
Can a principal be the AML/CTF compliance officer?
Yes. There is no requirement for the AML/CTF Compliance Officer to be a dedicated AML specialist. For real estate agencies, the principal licensee or a senior agent is the most common appointment. The Compliance Officer must be named in writing in your AML/CTF Program and be responsible for managing compliance, overseeing staff training, and making AUSTRAC notifications.
What are the penalties for real estate agencies that don't comply?
Under the AML/CTF Act 2006 (Cth), civil penalties for body corporates can reach up to $33,000,000 per contravention (based on current penalty unit rate of $330; re-indexes 1 July 2026). Criminal penalties apply for operating without enrolment and for serious non-compliance. AUSTRAC publishes all enforcement actions publicly, creating reputational consequences. Real estate agencies also face potential consequences with state licensing authorities.
Can Klyvon help me write a Suspicious Matter Report?
Yes. Klyvon Essential includes a suspicious matter report assistant. Enter the transaction date, transaction details, and the suspicious elements you observed. Klyvon drafts a formal, AUSTRAC-formatted SMR covering all six required sections — reporter obligations under the AML/CTF Act 2006, matter details, grounds for suspicion, suspicious indicators, recommended action, and AUSTRAC submission notes. You review and submit directly via AUSTRAC Online. Essential includes a high monthly draft allowance.
Does Klyvon include sanctions screening?
Targeted financial sanctions screening is now part of your AML/CTF program obligation under the AML/CTF Rules 2025 — not a separate exercise. Klyvon's generated program includes the required policy controls for targeted financial sanctions. You will still need to screen clients against the DFAT Consolidated List as part of your CDD workflow. Klyvon does not run live screening checks, but your program documents exactly when and how to do it.
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 your agency. This is a separate, mandatory requirement under the AML/CTF Act — distinct from your annual internal program review. The independent evaluation must assess: your ML/TF risk assessment against the Act and Rules, the design of your AML/CTF policies, your actual compliance with those policies, and whether you're appropriately identifying, assessing, and mitigating ML/TF risk. Findings go in a written report to your governing body or a responsible senior manager.
Build your agency’s AML/CTF program
The 29 July 2026 enrolment deadline is 21 days away.