AML Tranche 2 reforms for real estate: what agencies need to do before 31 March 2026

AML Tranch 2 real estate agents
AML Tranch 2 real estate agents

Australia’s anti-money laundering laws are about to land in real estate and the first step starts next week. 

From 31st March 2026, AUSTRAC enrolment opens for real estate businesses. 

For an industry that hasn’t previously been regulated under AML laws, this is the moment things shift from “something coming” to “something to act on”.  If you’re a Licensee in Charge, principal or agency owner, this is where preparation begins. 

This guide breaks it down in plain English - what’s changing, who it affects, and what you should be doing right now. 


What’s happening on the 31st March — and why it matters. 

From 31st March 2026: 

  • AUSTRAC enrolment opens for newly regulated real estate businesses 

  • Agencies can begin formally entering the AML/CTF regime 

  • Preparation moves from theory into action 

You are not required to enrol immediately but this is your starting line, not your deadline. Waiting until July will compress everything into a much harder, riskier rollout. 


What are the Tranche 2 AML reforms? 

Australia is expanding its Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws. Until now, these laws have applied mainly to banks, lenders and financial institutions. Tranche 2 extends these obligations into industries like real estate. This includes:

  • real estate agents

  • buyer’s agents

  • property developers

  • lawyers, accountants and other service providers

The aim is simple: close gaps that allow money to move through property transactions without scrutiny.


Why real estate is now in scope.

Property has long been seen as a high-risk channel for money laundering.  It involves: 

  • large transactions 

  • long-term asset growth 

  • the ability to obscure ownership through structures 

Real estate professionals sit in the middle of these transactions — which is why the industry is now being regulated. 


Who will be affected? 

If your business is involved in property transactions, you are likely in scope. This includes: 

  • agencies acting for sellers 

  • buyer’s agents 

  • developers selling property 

  • businesses brokering transactions 

In many cases, both the buyer and seller may be considered your “customer” under AML laws. 


What are “designated services”? 

You become regulated when you provide a “designated service”.  For real estate, this is broadly: Brokering the sale, purchase or transfer of property on behalf of another person. In practical terms: most agency activity will fall within scope. 


Key dates you need to know.

31 March 2026 

1 July 2026 

29 July 2026 

AUSTRAC enrolment opens 

AML obligations begin 


You must ensure your business is enrolled by this date


What agencies should be doing right now (before 31st  March).

This week is about getting your footing. Start with: 

  • confirming whether your business is likely to be regulated 

  • identifying who will own AML compliance internally 

  • understanding what AUSTRAC enrolment involves 

  • reviewing how you currently identify and verify customers 

You do not need a finished AML program yet. But you do need clarity on who, what and how before enrolment opens. 


What happens next (April to July).

After 31st March, the focus shifts to building your framework. That includes: 

  • enrolling with AUSTRAC 

  • developing your AML/CTF compliance program 

  • setting up customer due diligence processes 

  • identifying risk in your business 

  • preparing staff training 

AUSTRAC’s starter kit provides a structured way to do this, including risk, personnel and customer processes.


A major, but manageable shift. 

This is one of the biggest regulatory changes to affect real estate in years. But it doesn’t need to be overwhelming. Agencies that start early will embed this into normal operations. Agencies that delay will be rushing compliance under pressure. 


How Under The Hammer is supporting agencies 

At Under The Hammer, we work closely with real estate professionals navigating regulatory change. As the AML reforms approach, our focus is on helping agencies understand what this means in practice — not just in theory — and how it fits within their broader compliance responsibilities. 

We’ll continue sharing practical insights as more guidance becomes available. 

Our aim is simple: help agencies build compliance processes that are clear, workable and sustainable. 

 

This article provides general information only and should not be relied on as legal advice. All key dates referenced are based on AUSTRAC’s official guidance and published timelines.

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