AML CTF compliance checklist for real estate agents Australia 2026

AML/CTF Compliance for Real Estate Agents

April 05, 20263 min read

What You Need to Know Before 1 July 2026

From 1 July 2026, real estate agents and buyer's agents across Australia will be subject to significant new obligations under the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act. If you run an agency, this affects you directly and the time to prepare is now.

Why Property Is in the Spotlight

Real estate has long been flagged as a high-risk sector for financial crime. Property holds significant value, appreciates over time, and can generate income through rent or resale. These features make it attractive to those seeking to legitimise illegally obtained funds. Regulators are closing the gap by formally extending AML/CTF requirements to real estate professionals for the first time.

What You Need to Have in Place

Before facilitating any property sale, purchase, or transfer from 1 July 2026, your agency must have a formal AML/CTF program in place. We recommend aiming for May 2026 to give yourself time to review, refine, and train your team before the deadline hits.

Your program must be tailored to your agency's size and risk profile, and it needs to clearly document how you identify, assess, and manage risk. At a minimum, it should cover:

  • Customer identification: verifying who you are dealing with before you transact

  • Risk assessment: identifying high-risk clients, transactions, or jurisdictions

  • Ongoing monitoring: watching for unusual or suspicious activity across transactions

  • Record keeping: maintaining documentation that demonstrates your compliance

  • Staff training: making sure your team understands red flags and reporting obligations

You May Be Closer Than You Think

Many agencies already carry out identity checks and due diligence as part of everyday operations. The new requirements are not about starting from scratch. They are about formalising what you already do and housing it within a structured, documented compliance framework. The gap for most agencies is not in practice; it is in documentation and consistency.

The Upside of Getting It Right

Beyond meeting a legal obligation, a well-built AML/CTF program protects your business. It reduces your legal and reputational exposure, supports consistent and defensible decisions, and gives your team a clear process to follow. Compliance done well is a business asset, not just a box to tick.

Where to Start

Review your current procedures, identify the gaps, and build a written compliance program before the July deadline. AUSTRAC is your primary resource for requirements and guidance. Visit austrac.gov.au for their Real Estate Program Starter Kit, which walks small agencies through a four-step customisation process designed specifically for your sector.

Software tools to help you get there

Two platforms worth looking at as you build out your compliance program:

easyAML is an Australian-built platform purpose-made for Tranche 2. It covers risk assessment, staff training, customer due diligence, and ongoing monitoring in one place. They currently offer a free risk assessment and free staff training with no obligation, making it a practical starting point for smaller agencies.

First AML is a globally recognised AML and KYC platform operating across 180 countries. It is well suited to agencies managing higher transaction volumes or more complex client structures, with strong tools for identity verification, risk scoring, and audit-ready reporting.

Both platforms have dedicated real estate sections and are aligned with AUSTRAC's Tranche 2 requirements.

For a practical step-by-step guide to getting your agency ready, download our free AML Compliance Checklist - Click here


This article is for general informational purposes only and does not constitute legal advice. Please consult a qualified professional for advice specific to your business.

Kate Barnett is the founder of K8 Solutions, a property management consulting and systems design business based in Adelaide, South Australia. A Licensed Land Agent with nearly 20 years’ experience, she helps independent real estate agencies streamline operations, strengthen compliance, and build practical workflows using her Elev8 Framework.

Kate Barnett

Kate Barnett is the founder of K8 Solutions, a property management consulting and systems design business based in Adelaide, South Australia. A Licensed Land Agent with nearly 20 years’ experience, she helps independent real estate agencies streamline operations, strengthen compliance, and build practical workflows using her Elev8 Framework.

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