AML/CTF Program
Written policies covering risk assessment, CDD procedures, transaction monitoring, and staff training—tailored to your agency.
Real Estate
Aml Compliance For Real Estate Agencies
AML compliance for real estate agencies - Learn about AUSTRAC requirements and AML/CTF obligations for real estate agents and property professionals.
Key Information
AUSTRAC Requirements
According to AUSTRAC guidance, aml compliance for real estate agencies is a critical requirement for real estate agents and property professionals. AUSTRAC has identified real estate as an established money laundering channel in Australia, highlighting the sector's vulnerability to exploitation by criminals seeking to legitimize illicit funds through property transactions.
From 1 July 2026, AML/CTF obligations will apply to certain services typically provided by real estate professionals including real estate agents, buyer's agents and property developers under the Tranche 2 reforms. These reforms extend Australia's anti-money laundering and counter-terrorism financing regime to designated non-financial businesses and professions, aligning with international standards set by the Financial Action Task Force.
AUSTRAC requires real estate professionals to enroll as reporting entities by 29 July 2026, with enrollment opening from 31 March 2026. Businesses must not provide designated services before completing their enrollment. Criminal penalties apply for non-compliance with enrollment requirements.
Real estate agencies will need to develop and maintain a written AML/CTF program that protects their business from criminal exploitation through money laundering, terrorism financing and proliferation financing. The program must be documented and approved by senior management before providing any designated service, and must be appropriate to the nature, size and complexity of the business. The program must be kept up to date to reflect significant changes to the business and changing money laundering and terrorism financing risks.
Key components include appointing an AML/CTF compliance officer at management level who is fit and proper, conducting initial and ongoing customer due diligence to verify customer identities, implementing transaction monitoring systems to detect suspicious activity, and submitting required reports to AUSTRAC within specified timeframes. All records must be maintained for at least seven years to provide evidence of due diligence, risk management practices and compliance with AML/CTF obligations.
The reforms acknowledge that criminals buy real estate to launder or conceal illicit funds, as property transactions allow the movement of large amounts of money in a single transaction. Laundering illicit funds through the real estate sector not only allows criminals to conceal and enjoy profits from their crimes, but also poses risks that property prices may be artificially inflated, creating hardship for genuine property buyers seeking affordable housing.
Key Compliance Requirements
Buyer & Seller CDD
Verify identity of buyers and sellers, identify beneficial owners of companies/trusts, and understand source of funds.
Source of Funds
Document how buyers intend to fund purchases—deposits, finance approvals, cash components. Flag high-risk arrangements.
Transaction Triggers
Obligations begin when transaction expected to proceed—typically at contract signing. CDD required before settlement.
Suspicious Reporting
Report ML/TF suspicions to AUSTRAC within 24 hours (terrorism) or 3 days (other). Cannot tip off clients.
Record Retention
Keep customer ID, transaction records, and compliance documentation for 7 years after relationship ends.
Frequently asked questions
Which real estate services trigger AML obligations?
Brokering the sale, purchase or transfer of real estate triggers obligations. This includes residential, commercial, rural, and industrial property sales. Property management (rentals) is NOT a designated service.
When exactly do obligations begin for a transaction?
When it's reasonably expected the transaction will proceed—typically when the buyer's offer is accepted and contracts are signed. You must complete CDD on buyers and sellers before settlement.
What source of funds documentation is required?
Document how buyers will fund the purchase: bank statements for deposits, loan pre-approvals, evidence of asset sales, inheritance documentation. Flag cash purchases or third-party funding as higher risk.
Are private property sales captured?
No. Private sales of residential property by individuals and incidental sales by businesses (e.g., a company selling its premises) are not designated services under the reforms.
What are red flags for money laundering in real estate?
Large cash deposits, third parties providing funds, rapid buy-sell transactions, overseas buyers with no local presence, complex company structures, purchases significantly over/under market value, and buyers indifferent to property condition.
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