AUSTRAC Tranche 2 AML/CTF Obligations (2026)
Under Tranche 2 reforms, real estate agents involved in property transactions, deposits, or client fund handling are now captured under the AML/CTF Act. This page explains exactly what you must do to comply.
Learn more in the AML/CTF Guide.
You are captured if you provide any **designated service**, including:
Handling deposits or trust account funds
Managing property settlements or transfers
Acting as an intermediary in high‑value transactions
Conducting identity verification for buyers or sellers
Managing overseas or high‑risk clients
Assisting with company or trust structures for property purchases
If you perform any of these activities, you must comply with the AML/CTF Act — regardless of agency size.
You must maintain a written AML/CTF Programme outlining governance, risk assessment, controls, and CDD procedures.
You must assess the money laundering and terrorism financing risks associated with your clients, transactions, and services.
You must verify client identity, understand the purpose of the transaction, and apply enhanced due diligence for high‑risk clients.
You must report suspicious matters to AUSTRAC within 3 business days (or 24 hours for terrorism‑related matters).
You must keep AML/CTF records, CDD evidence, and SMR logs for at least 7 years.
You must monitor client activity, update risk assessments, and review your AML/CTF Programme annually.
See full requirements in the AML/CTF Guide.
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