What's Changing and Why?
Australia's AML/CTF regime is being expanded to cover additional higher-risk services ("tranche 2"), including certain real estate services. This significant regulatory change reflects the government's commitment to strengthening Australia's defences against money laundering and terrorism financing, bringing the real estate sector in line with international standards and FATF recommendations.
The reform is delivered through the AML/CTF Amendment Act 2024 and updates the framework under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.
Are You In Scope?
You're in scope if you provide a designated service with a geographical link to Australia.
For real estate, AUSTRAC's reform guidance indicates designated services include:
Minimum Viable Compliance by 1 July 2026
What you must have in place by the deadline:
- Enrolment readiness/completion
- An AML/CTF Program in place
- An appointed AML/CTF Compliance Officer with authority to implement the program
- Staff training completed and embedded in onboarding/operations
- Operational readiness to report suspicious matters
Key Dates You Must Plan To
Enrolment Opens
Registration with AUSTRAC becomes available (cannot be done earlier)
Obligations Commence
Tranche 2 comes under regulation; real estate designated services become regulated
Enrolment Deadline
Final deadline to complete AUSTRAC enrolment
How Austris Compliance Advisory Supports
Scoping + Operating Model
Confirm which business lines are designated services and define 'customer' and 'when KYC happens' triggers. Build the RACI (frontline vs compliance vs management sign-off).
AML/CTF Program + Risk Assessment
Draft a fit-for-purpose AML/CTF Program. A practical risk assessment approach that operations can run.
Compliance Officer (CO) Enablement
CO role design, governance cadence, escalation pathways, regulator engagement support.
Training + Go-live Readiness
Role-based training, onboarding pack, refresher cadence, assessment/attestation evidence.
CDD + Reporting Readiness
KYC templates, evidence standards, data quality controls, and suspicious matter reporting workflow.
Let's Start Your Compliance Journey
Get in touch to discuss how we can help your real estate business prepare for Australia's AML/CTF requirements.
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