For Real Estate Agents
AML/CTF Compliance for Australian Real Estate Agencies
Real estate is one of the highest-risk sectors identified by AUSTRAC for money laundering. From 1 July 2026, licensed real estate agents providing designated services in Australia are reporting entities. AML SoftServe gets your agency enrolled, compliant and running.
What changed on 1 July 2026
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024brought real estate professionals under AUSTRAC's AML/CTF regime as part of Tranche 2. Enrolment opened 31 March 2026, obligations commenced 1 July 2026, and agencies already providing designated services on that date must enrol with AUSTRAC by 29 July 2026.
Which real estate activities are designated services?
An agency is captured when it acts in relation to the sale, purchase or transfer of real estate. The typical designated-service touchpoints for selling agents are:
- Marketing a property for a vendor
- Introducing a purchaser to a vendor
- Preparing or facilitating a contract of sale
- Receiving or holding deposit funds in trust
- Assisting with property transfers between related parties
- Managing off-market or private-treaty sales
Note: property management (leasing / rentals) is generally nota designated service. If your agency does both sales and property management, only the sales side is captured. Buyers' agents have distinct obligations — see the buyers' agents page.
What your agency must do
Enrol via AUSTRAC Online
You will need your ABN, the state real estate licence number for every jurisdiction your agency operates in (REI licence, estate agent authority, Property Occupations licence — the label varies by state), a list of the sales-side designated services you provide, and your Compliance Officer’s details. Franchise offices generally enrol as separate reporting entities from the group. Existing agencies enrol by 29 July 2026; new agencies within 28 days of the first captured listing or exchange.
Verify vendor at listing, purchaser at exchange
Before you sign the listing agreement, verify the vendor’s identity and, for corporate or trust vendors, the beneficial owners at the 25 percent threshold. Before contracts exchange, verify the purchaser and their beneficial owners. At-auction pressure is real — build ID collection into your bidder registration or paddle-number process, not after the hammer falls. Anonymous or last-minute bidders are a red flag, not a sales opportunity.
Build a program around AUSTRAC’s real estate risk assessment
Your program must reflect your actual mix — residential-only vs mixed residential/commercial, on-market vs off-market, single office vs franchise network. AUSTRAC’s real estate sector risk assessment flags off-market and cash-adjacent settlements, premium-segment coastal residential, and multi-layered foreign-controlled corporate purchasers as elevated risk. Your program must address each of those explicitly, not with a generic template.
Rate risk by segment, channel and purchaser type
Segment your Risk Mitigation Plan across property tier (median residential vs premium/luxury vs commercial), sale channel (public auction, private treaty, off-market, expression of interest), and purchaser profile (owner-occupier, domestic investor, corporate/trust, foreign purchaser under FIRB). Refresh whenever you push into a new segment — rural, luxury waterfront, off-plan pre-sales, or corporate divestments.
Train every touchpoint, not just principals
Licensed principals, sales representatives, PAs and BDMs who take enquiries, auction callers, off-market negotiators — anyone with a designated-service touchpoint must be trained before they act. Franchise networks: head-office training does not automatically cover new offices’ staff. Track competency by individual, refresh annually, and keep evidence in a form your independent evaluator can pull in one export.
Watch for the sale-specific red flags AUSTRAC lists
SMRs are due within 24 hours if terrorism financing is suspected, otherwise within 3 business days. The pattern-matching AUSTRAC calls out for real estate: purchasers who show no interest in the property itself, cash-adjacent settlements structured just below reporting thresholds, sudden name changes on the buyer side before exchange, and beneficial ownership structures that seem disproportionate to the purchase price. Records retained for 7 years — well past the sunset on your listing agreement.
How AML SoftServe fits a real estate agency
- AML/CTF Program pre-tuned to AUSTRAC’s real estate sector risk assessment — off-market cash-adjacent sales, premium coastal residential, foreign-controlled corporate purchasers and multi-layered trust buyers are already coded as elevated risk in your program from day one.
- Vendor-and-purchaser CDD workflow that fits your existing sales pipeline — from listing agreement through to exchange — so ID collection happens at the natural pause points (listing signing, bidder registration, contract preparation) instead of slowing down auction day.
- Beneficial-ownership capture for corporate purchasers, family trusts and SMSF buyers — the ownership vehicles that dominate the premium residential segment where AUSTRAC scrutiny is highest.
- Continuous PEP, sanctions and adverse-media screening — new hits flagged to your CO in real time, so a purchaser who lands on a sanctions list between offer and settlement doesn’t slip through your closing checklist.
- Staff training built for real estate roles — licensed principals, sales representatives, PAs / BDMs, auction callers and off-market negotiators — with completion tracking that survives franchise-network audits and doesn’t assume head-office training carries across to new offices.
- Optional Compliance Officer support — our team runs vendor and purchaser CDD for your agency so your principals stay focused on listings and settlements, not ID collection or beneficial-ownership tracing.
- AUSTRAC-review-ready audit trail with 7-year retention — every CDD file, every SMR draft, every training completion and every risk rating change is exportable in one click, well beyond the sunset on any listing agreement.
Pricing for real estate agencies
Path 1 is $1,250 one-off setup with $0/month platform fee. Path 2 is $90/month with Compliance Officer support. Full detail on the pricing page.