For the past few months, the real estate industry has been talking about AML. Now we’re approaching the point where agencies need to move from awareness to implementation. 

From 1 July 2026, real estate businesses providing designated services will become subject to Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) framework. 

Most agencies are aware that change is coming. The bigger question is what those changes will actually mean inside a real estate business. This isn’t about legal interpretation. It’s about understanding the practical and operational changes agencies will need to manage from 1 July onwards. 

What Changes on 1 July 2026? 

From 1 July 2026, real estate agencies providing designated services may be required to: 

✓ Conduct customer due diligence 

✓ Operate under an AML/CTF program 

✓ Establish governance and compliance responsibilities 

✓ Train staff on AML obligations 

✓ Report suspicious matters 

✓ Maintain AML records and documentation 

For many agencies, this represents one of the most significant compliance changes to affect the industry in years. 

Customer Due Diligence Will Become Part of Everyday Agency Workflows 

Most agencies already collect identification from buyers and sellers. What changes under the AML framework is the purpose behind it. 

Customer Due Diligence (CDD) requires agencies to understand who their customers are and assess the level of risk they may present. In practical terms, agencies will need processes to: 

• identify customers 

• verify information 

• assess potential risk factors 

• determine whether additional checks may be required 

For some customers, the process may remain relatively straightforward. For others, agencies may need additional information or enhanced due diligence before proceeding. 

Customer identification is no longer simply an administrative task. It becomes part of a broader risk management framework. 

 The Definition of “Customer” May Be Broader Than You Think 

One of the areas causing confusion across the industry is understanding who the customer actually is. Under AUSTRAC’s real estate guidance, both parties to a property transaction may become relevant to an agency’s AML obligations. 

That means agencies may need to think differently about how they collect information, assess risk and document decisions throughout a transaction. For businesses that have traditionally focused on the party engaging their services, this represents a significant shift in thinking. 

Real Estate Agencies Will Need AML Governance and Oversight 

AML compliance is not simply a policy sitting on a shelf. AUSTRAC expects businesses to establish clear governance arrangements around how AML responsibilities are managed. 

This includes identifying who is responsible for overseeing compliance and ensuring processes are being followed. For many agencies, this responsibility will likely sit with: 

• the Licensee in Charge 

• the principal 

• a senior operations leader 

• an appointed AML/CTF Compliance Officer 

In smaller businesses, one person may hold multiple responsibilities. What matters is that ownership is clearly defined. Without clear accountability, implementation becomes difficult. 

Staff Training Will Become Increasingly Important 

Technology, systems and policies are only part of the equation. Compliance is ultimately delivered by people. From 1 July, agencies should expect staff to have a basic understanding of: 

• what AML obligations are 

• how customer due diligence works 

• what unusual behaviour may look like 

• when concerns should be escalated 

• who is responsible for decision-making 

This does not mean turning agents into compliance specialists. It means making sure the people interacting with customers understand the processes they are expected to follow. 

 AML Record-Keeping Requirements Will Increase 

Another significant operational change involves record keeping. Agencies will need processes to manage and retain information relating to: 

• customer due diligence 

• risk assessments 

• AML decisions 

• designated services 

• ongoing compliance activities 

This is about more than storing documents. It is about being able to demonstrate how decisions were made and how obligations were managed over time. For many businesses, this will require a more structured approach than currently exists. 

The Agencies That Will Be Most Comfortable After 1 July 

The agencies that handle this transition best are unlikely to be the agencies with the biggest budgets or the most sophisticated technology. They will be the agencies that have: 

• assigned ownership 

• documented processes 

• trained staff 

• established practical workflows 

• started implementation early 

AML compliance does not need to be complicated. But it does need to be intentional. The businesses that treat AML as an operational project rather than a last-minute compliance task are likely to be in a much stronger position. 

A Practical Question for Every Licensee in Charge 

If someone asked your agency tomorrow: 

“Who is responsible for AML, how do we identify risk and what happens when a concern is raised?” 

Would everyone in the business give the same answer? If not, that may be the best place to start. 

How Under The Hammer Is Supporting Agencies 

At Under The Hammer, we’re seeing agencies move beyond simply understanding the reforms and into implementation. The challenge is no longer awareness. 

It’s translating regulatory requirements into practical processes that work inside a real estate business. 

Our focus is helping agencies understand what these changes mean operationally and how they fit within the broader compliance responsibilities of a modern agency. 

As implementation continues across the industry, we’ll continue sharing practical insights designed to help agencies prepare with confidence. 

This article provides general information only and should not be relied upon as legal advice. Agencies should seek professional advice where appropriate.