From 1 July 2026, real estate agents, buyer’s agents, property developers, and conveyancers face new AML/CTF obligations under AUSTRAC’s Tranche II reforms. Is your business ready?
The AML/CTF regime does not regulate entire industries. It regulates specific designated services. For real estate professionals and conveyancers, the core question is: are you acting on behalf of a client in a transaction involving the buying, selling, or transfer of real property?
Real estate agents and buyer’s agents are captured when they broker, plan, or execute the sale, purchase, or transfer of real estate on behalf of a client.
Conveyancers are captured when they prepare contracts, conduct title searches, hold funds in trust, or otherwise directly advance a property transaction — even if the transaction does not ultimately complete.
Property developers may be captured where they assist in the transfer of property on behalf of clients or purchasers.
Conveyancers — a common misconception: Even providing conveyancing services to a family member, for no fee, on a one-off basis, will likely be captured if it directly advances a property transaction. The test is the nature of the service — not who it is provided to or whether a fee is charged.
AUSTRAC has confirmed that AML/CTF obligations can be triggered before a transaction is completed — including during preparatory steps such as conducting title searches or holding deposit funds in trust. The obligation begins when you take steps to advance the transaction, not when settlement occurs.
Legal practices that provide both legal services and conveyancing services face a dual obligation. AUSTRAC has confirmed that such practices will need to maintain two separate risk assessments — one under the Legal Profession Starter Kit and one under the Conveyancing Starter Kit. WilliamThomas&Co. can manage both simultaneously and efficiently.
| Obligation | What It Means for Your Business |
|---|---|
| Enrol with AUSTRAC | Register via the AUSTRAC Business Portal from 31 March 2026. Deadline: 29 July 2026. |
| ML/TF Risk Assessment | Identify and document your money laundering and terrorism financing risks — tailored to your clients, services, and geographies. |
| AML/CTF Program | A written, risk-based compliance program covering your policies, procedures, controls, and staff training obligations. |
| Customer Due Diligence (CDD) | Identify and verify every client before providing a designated service. Enhanced checks required for high-risk clients and Politically Exposed Persons (PEPs). |
| Ongoing Monitoring | Continuously monitor client relationships and transactions for suspicious activity throughout the engagement. |
| Suspicious Matter Reporting | File Suspicious Matter Reports (SMRs) with AUSTRAC promptly when required. Failure to report is a serious criminal offence. |
| Record Keeping | Retain identity verification and transaction records for a minimum of seven years. |
| Appoint a Compliance Officer | Designate a qualified AML/CTF compliance officer and notify AUSTRAC by 29 July 2026. |
| Date | Milestone |
|---|---|
| 31 March 2026 | AUSTRAC enrolment portal opens for Tranche II entities. |
| 1 July 2026 | All AML/CTF obligations commence. Your program must be fully operational from this date. |
| 29 July 2026 | Final deadline to complete AUSTRAC enrolment and notify your nominated compliance officer. |
Property is one of the most widely exploited channels for money laundering globally, and Australian real estate has been specifically identified in AUSTRAC’s National Risk Assessment as a key vulnerability. Common methods include:
Australia was the last FATF member country to bring real estate professionals into the AML/CTF regime. That period of unregulated exposure ends permanently on 1 July 2026.
WilliamThomas&Co. offers a no-obligation Tranche II scoping consultation. With less than four months to the 1 July 2026 deadline, early action is the only safe strategy.