AUSTRAC Tranche 2 for Real Estate Agents: Complete AML Compliance Guide 2026

Real estate agents and property professionals are among the highest-risk sectors for money laundering. From 1 July 2026, AUSTRAC requires all real estate professionals who assist in the sale, purchase or transfer of property to comply with AML/CTF obligations.

Why real estate is high risk for money laundering

Property transactions are commonly used to launder proceeds of crime because they involve large sums, can involve complex ownership structures, and records are publicly available. AUSTRAC has identified real estate as a nationally high-risk sector.

Which real estate services are captured?

You must comply with AML/CTF obligations when providing any service in connection with:

• The sale or purchase of real estate (buying or selling agent)
• The transfer of real estate
• Property management involving handling client funds

This applies regardless of the property value — there is no dollar threshold.

KYC for property buyers and sellers

You must verify the identity of both the buyer and the seller before you start providing a designated service. For company or trust buyers, you must verify the entity and every beneficial owner (anyone with 25%+) and director or trustee.

For most transactions, this means biometric identity verification — the client uploads their ID and takes a selfie, which is matched against government records. This takes 2–5 minutes.

Third-party payers — a key red flag

One of AUSTRAC's most important indicators for real estate is third-party payments — when the deposit or purchase price is paid by someone other than the buyer. This is a major red flag and should be documented and potentially reported as a suspicious matter.

Suspicious Matter Reports for real estate

You must file an SMR with AUSTRAC within 3 business days of forming a suspicion that a transaction may be connected to criminal activity. Red flags include: cash deposits, overseas funds from high-risk jurisdictions, buyers who show little interest in the property, and rapid resale patterns.

Record keeping requirements

All KYC records, risk assessments, screening results and SMRs must be retained for 7 years. AUSTRAC can request these at any time during a compliance review.

Related reading: AML risk assessment guide · Customer due diligence explained · AUSTRAC Tranche 2 complete guide · Frequently asked questions