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AML compliance real estate agents Australia

AML Compliance for Real Estate Agents: AUSTRAC Tranche 2 Explained

Property transactions are a major AML focus, which means agencies need a practical program before the deadline pressure peaks.

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Are you affected?

If your agency brokers property sales or related designated services, AUSTRAC Tranche 2 is expected to bring your business into scope and require compliance by 1 July 2026.

Your obligations

  1. Enrol with AUSTRAC now that enrolment is open
  2. Build an AML/CTF program tailored to your services
  3. Implement customer due diligence procedures
  4. Train staff on red flags and process
  5. Maintain records and reporting readiness
Coastal Property Group Licensed Real Estate Agency · ABN 55 123 456 789 · Gold Coast QLD AML/CTF Risk Assessment — Prepared by Assemble Compliance ASSEMBLE ML/TF RISK ASSESSMENT — BUYER: AHMED AL-RASHID — CPG-2026-0217 SECTION 1 — TRANSACTION DETAILS BUYER NAME Ahmed Al-Rashid PROPERTY 42 Ocean Drive, Surfers Paradise PRICE $3,200,000 TRANSACTION TYPE Residential property purchase — off-the-plan apartment, settlement in 6 months SECTION 2 — ML/TF RISK FACTOR ASSESSMENT RISK FACTOR ASSESSMENT RISK RATING Customer type Non-resident individual, overseas buyer HIGH Service/product type High-value residential property purchase HIGH Delivery channel Remote — video call + email only, no in-person MEDIUM Foreign jurisdiction Buyer based in UAE, funds from Dubai bank HIGH PEP / Sanctions status Not a PEP. No sanctions match — screening complete. LOW Transaction value $3.2M — significantly above threshold HIGH Source of funds Overseas bank transfer — source evidence requested HIGH OVERALL ML/TF RISK RATING: HIGH Enhanced CDD mandatory SECTION 3 — ASSESSOR NOTES High-risk: offshore buyer, high value, overseas funds. Enhanced CDD applied. Source of funds statutory declaration requested. Assessed by: Mark Sullivan, Principal Agent Date: 8 May 2026 SAMPLE by Assemble Compliance — assemblecompliance.com.au
Sample high-risk property transaction assessment demonstrating enhanced due diligence.

In scope

  • Residential and commercial property sale services
  • Buyer-side transaction assistance tied to property deals
  • Handling transaction-related customer due diligence
  • Agency processes involving designated real property services
  • High-risk client onboarding for property transactions
  • Staff workflows tied to settlement-stage customer checks

Out of scope

  • Pure rental management
  • General property marketing only
  • Standalone advertising services
  • Administrative support with no designated service
  • Property photography and listing production
  • Unrelated business consulting

The risk of waiting

Waiting compresses everything: scope assessment, drafting, review, training, enrolment admin, and implementation. That is how firms end up rushing the most important part.

How we help

We package the work into a fixed-scope build so your team is not trying to interpret guidance, draft procedures, and pressure-test scope at the same time.

Do real estate agents need AML compliance?

That is the expected outcome of Tranche 2. Agencies should prepare now rather than waiting for the final rush.

What property transactions are in scope?

Sale-side and transaction-related services are the key area to review, not ordinary marketing support work.

Why act now if enrolment is already open?

Because enrolment is only one step. Agencies still need a finished program, procedures, training, and implementation time before 1 July.

Primary action

Build My Compliance Program

Start with the short form. We review the details, check likely scope, and respond personally with the right next step for your real estate agents firm.

What happens after you submit?

  1. We review your firm, services, and likely AML/CTF scope.
  2. We identify the fastest path to a compliant program and likely package fit.
  3. You get a personal reply from Assemble Compliance with next steps.

No obligation. No hard sell. We review your firm first and reply personally.


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