AML Compliance for Real Estate Agencies

Helping agency leaders understand Tranche 2 reforms — and what they mean for your business operations

At a glance: AML/CTF reforms for real estate professionals

Australia’s AML/CTF reforms have been expanded to include real estate agencies. It means new reporting responsibilities for agencies involved in property transactions. The changes aim to strengthen transparency and accountability in existing business workflows.

What's happening?

Real estate agencies are included under Australia’s AML/CTF framework as part of Tranche 2 reforms, increasing regulation and reporting for property-related transactions.

What do I need to do?

Understand your AML/CTF obligations, verify client identities, assess risk, keep appropriate records and report any suspicious activity to AUSTRAC.

When will this happen?

Reporting entities are required to enrol from 31 March 2026, and obligations commence from 1 July 2026.

Why the property market is under the spotlight?

High monetary value transactions and complex ownership structures that make it difficult to trace the beneficial owner contribute to real estate’s appeal to money launderers.

To address this risk, Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) framework has been expanded to include property-related services under the Tranche 2 reforms.

Agency owners will play a bigger role in helping to identify suspicious activities and the true identities of clients, and ensure property transactions are legitimate and transparent. The reforms aim to build trust in the property market while aligning Australia with international standards.

Key obligations for your agency

This section contains the core AML/CTF obligations that real estate agencies will be required to meet under Tranche 2 reforms. It provides a high-level view of what the law requires, so agency leaders can understand their responsibilities before planning their next steps.

Under the new reforms, being aware of AML/CTF risks isn’t enough for Tranche 2 entities. Agencies included in these reforms must take active steps to manage risks through documented programs and frameworks, consistent and transparent processes, ongoing oversight and independent evaluation.

Key responsibilities for your real estate agency

AML compliance in practice

AML/CTF compliance needs to be part of an agency’s daily operations. Practically, this means building simple checks and awareness into existing workflows, so risks can be identified early and managed consistently across transactions and clients.

What this means for real estate agents, day to day

AML obligations will appear across familiar processes, such as onboarding new clients and managing payments and settlements. Below are common touchpoints and how AML compliance may apply in practice.

Onboarding new clients

When onboarding a new vendor, buyer, landlord or commercial client, agencies will need to verify the true identity of the client and understand who the client is acting on behalf of if they’re
dealing with a representative.

Example: A company structure is listing a commercial property. Your agency may need to identify the beneficial owner, not just the company representative signing the agreement.

Purpose of transaction

Agencies are required to understand why a transaction is taking place and if it aligns with the client’s profile.

Example: If a residential property is purchased above market value without a clear explanation, the agency will need to investigate why.

Deposits and payments

Agencies should be alert to unusual payment methods or patterns, such as payments being made from multiple third-party bank accounts or from an unrelated overseas entity without supporting documentation or explanation.

Trust account use

Where agencies use trust accounts to hold funds, they need to present clear records and be transparent about where funds are received from and paid to.

Example: A last-minute change to payment instructions involving a new third party may need closer review.

Transaction monitoring

Agents must remain alert throughout the sale process, not just at the beginning. Look out for unusual activities such as: requests for fast settlements without commercial reasoning or frequent changes to payment sources and ownership details.

Property management activities

AML obligations also apply to property management activities, especially where payments are ongoing.

Example: Rental payments being made from multiple unrelated accounts or offshore sources may need further attention.

Why real estate agents choose PEXA Clear

Australian-built for Tranche 2

Designed specifically for how Australian property transactions work, not adapted from a global tool.

Accurate risk assessments

Protect client relationships — only flags genuinely medium or high-risk activity, so your clients aren't needlessly disrupted.

Audit-ready from day one

Every check and decision is documented automatically as you work.

See how PEXA Clear works

Learn more about PEXA Clear Register