AML/CTF for Real Estate Agents: What Agencies Must Have in Place by 1 July 2026

From 1 July 2026, real estate agencies that broker the sale, purchase, or transfer the property become reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) (AML/CTF Amendment Act). Property developers who sell directly to buyers without an independent agent are also captured.

Real estate is a focus of the reforms for a simple reason: property has long been one of the main channels for laundering money in Australia, and until now the professionals at the centre of those transactions have had no obligation to look for it. That changes in a matter of weeks, and agencies have a shorter, more specific to-do list than most realise. This guide works through it.

What exactly is captured?

The obligations attach to two designated services in Table 5 of the AML/CTF Act.

What is not captured matters just as much:

A combined sales and property management agency is still a reporting entity because of its sales arm; the program just needs to reflect that the obligations sit on the sales side.

The point most agencies get wrong: who your customer is

Under the brokering service, your customer is both the seller and the buyer, regardless of who appointed you. AUSTRAC’s guidance is direct about it: when an agent acts for the seller and brokers a successful sale, the customer is both parties.

What changes is when your obligations to each side begin:

This means vendor due diligence happens at listing, and buyer due diligence happens in the window between acceptance and exchange. For auctions, where the buyer is only known at the fall of the hammer, AUSTRAC permits delayed initial customer due diligence where completing it beforehand would disrupt the ordinary course of business. The check still has to happen, but the timing flexes, not the obligation.

The six obligations, with deadlines

Note the trap: 29 July is the enrolment backstop, but the program, the compliance officer, and the CDD workflow must be operating from 1 July. Treating 29 July as the real deadline leaves four weeks of designated services with no compliance framework behind them.

What customer due diligence looks like on a sales file

If those matters cannot be established, the service cannot proceed. For everyday domestic transactions with Australian-resident individuals, this resolves to a tight workflow of verifying identity, screening, risk-rating, and recording.

The files that need more are exactly the ones you would expect, for example, company and trust buyers, overseas-based parties, unusual settlement structures, and buyers whose funds do not match their profile.

Cash is its own obligation. Receiving $10,000 or more in physical currency triggers a threshold transaction report within 10 business days. AUSTRAC’s worked example is an agency receiving a $21,250 cash deposit. Electronic transfers do not trigger TTRs.

If a buyer offers to split a large cash deposit into several smaller payments to stay under the threshold, that is structuring, and it is precisely what a suspicious matter report is for. AUSTRAC’s structuring example is also set in a real estate agency.

Because leasing is not a designated service, cash received for rent or bonds sits outside TTR territory on the current framing, though agencies handling significant cash rent should confirm their position with AUSTRAC or a compliance adviser rather than assume it.

A four-week readiness plan

AUSTRAC’s updated statement of regulatory expectations (21 May 2026) sets the bar for day one: be enrolled, have a program and compliance officer, train staff, and be ready to "have a go" at reporting. It also offers two reassurances. AUSTRAC expects "effort, not perfection" during the first year. Agencies that match the real estate program starter kit profile and use it as designed can expect AUSTRAC’s engagement to focus on how they apply the program, not whether they should have designed a different one.

Week 1: Enrol and appoint. Enrol the licensee entity on AUSTRAC Online. Designate the compliance officer, usually the licensee-in-charge or principal, document the fit-and-proper assessment, and notify AUSTRAC. REIQ’s enrolment fact sheet walks through the portal step by step.

Week 2: Build the program. Download the starter kit, work through the risk assessment honestly (your suburb mix, buyer profile, cash exposure, trust and company transactions, overseas-based parties), and customise the policies to match how your office actually runs files. The kit is designed for agencies of 15 or fewer people doing standard brokering work; larger or more complex agencies need to adapt and document why.

Week 3: Wire CDD into the sales workflow. Decide who runs verification at listing and at contract, what tool they use, where the records live, and how a high-risk result escalates to the compliance officer. The aim is that an agent cannot take a file to exchange without the CDD step existing.

Week 4: Train and dry-run. Brief every agent and admin staff member on the program, the red flags and the reporting workflow. Run one or two recent sales files through the new process end to end. Book the team into AUSTRAC’s free induction webinars, and check your state institute’s training calendar; REIQ, REINSW and REIV all run dedicated AML programs.

Download this guide

A print-ready PDF of this compliance checklist is available to download and bring to your next sales meeting.

Share it with your principal, licensee-in-charge and sales team.

Where VeriEzi fits

Almost everything above is process and accountability. The repetitive part is verifying two parties on every sale, screening them, rating the risk, and keeping the records straight. That is the part worth automating, and it is what VeriEzi does.

VeriEzi verifies vendors and buyers in one flow. The client receives a link, completes a short questionnaire, and verifies their identity in 5 languages, with no app to download. That last part matters in real estate, where overseas-based buyers and sellers are routine; VeriEzi handles offshore verification natively, including for clients on WeChat and Alipay.

Screening runs across 300+ global databases covering sanctions, politically exposed persons and adverse media. Each matter auto-calculates a risk level, and high-risk results escalate to your compliance officer. Cash threshold transactions are flagged for TTR lodgement, suspicious matter reports pre-fill from the matter record, and the audit trail exports to CSV whenever someone asks to see it.

Pricing fits how agencies actually work: no subscription and no platform fee. You pay per verification, so a quiet month costs you almost nothing. You can get 5 free verifications to run on live sales files, or book your free demo and see the vendor-and-buyer workflow before 1 July.