Real estate’s new reality: AML/CTF overhaul, fresh funding and what it means for agents

Contributed By: TheOnsiteManager.com.au on

Brisbane, 26 August 2025 — Australia’s real estate sector is hurtling toward its biggest compliance shake-up in decades, with the federal government confirming that anti-money laundering and counter-terrorism financing (AML/CTF) obligations will extend to real estate professionals from 1 July 2026. The reforms—passed by Parliament in late 2024 and now being implemented by AUSTRAC—will require agencies to enrol with the regulator, build risk-based compliance programs, verify clients, file suspicious matter reports, and keep detailed records. (AUSTRAC)

Under AUSTRAC’s published timetable, enrolment for newly regulated businesses opens on 31 March 2026, giving agencies a short runway to formalise systems before the legal start date. AUSTRAC has also flagged “core guidance” for new entrants in October 2025, aimed at demystifying obligations, programs and reporting. (AUSTRAC)

What changes on the ground

For real estate professionals—defined by AUSTRAC to include real estate agents, buyers’ agents and property developers—the key new obligations are clear: (1) enrol with AUSTRAC, (2) implement and maintain an AML/CTF program tailored to your business, (3) conduct initial and ongoing customer due diligence, (4) report certain transactions and suspicious activity, and (5) keep prescribed records for at least seven years. Those obligations are risk-based, meaning procedures should scale to the size, services and risk profile of each agency. (AUSTRAC)

The reforms are part of a broader modernisation push that saw the AML/CTF Amendment Bill 2024 pass both houses on 29 November 2024, receiving Royal Assent on 10 December 2024. Government agencies have since been rolling out guidance, exposure drafts of updated Rules and staged industry consultations to smooth the transition for so-called “tranche 2” entities, which include real estate alongside lawyers, accountants, conveyancers and others. (AUSTRAC)

Who pays for the uplift?

To help fund the reform and enforcement effort, the 2024-25 Federal Budget earmarked $167.8 million to support implementation of the AML/CTF overhaul and strengthen Australia’s defences against financial crime. While that is central funding, AUSTRAC also operates an industry contribution levy on some reporting entities to recover a portion of its operating costs. Crucially for smaller agencies, AUSTRAC says the levy “usually” applies only to medium and large businesses—typically those with earnings of A$100 million or more or very high reporting volumes. (Grant Thornton AustraliaAUSTRAC)

In other words, the day-to-day cost of getting compliant—drafting programs, conducting KYC, training staff, and potentially investing in regtech—will sit with agencies, but most small and mid-sized firms are unlikely to receive an AUSTRAC levy invoice based on current settings.

Industry reaction: support, with warnings on red tape

The Real Estate Institute of Queensland (REIQ) says it backs the objectives of stronger safeguards but wants a practical, proportionate regime that recognises the sector’s structure.

“We fully support the Government’s commitment to protecting the integrity of the Australian financial system,” REIQ CEO Antonia Mercorella said. “However, the proposed framework doesn’t fully take into account the practical challenges faced by real estate businesses—namely the lack of resources and specialised expertise needed to meet these complex compliance requirements.” (REIQ)

Ms Mercorella noted most Queensland agencies are small, independent operations and warned that compliance costs are unlikely to be absorbed without flowing through to consumer prices. She advocated a more collaborative, technology-enabled model that lets “tranche 2” professionals share verified information, with VOI and frontline monitoring handled by agents while complex tasks like source-of-funds/wealth checks and PEP identification sit with legal and accounting specialists. (REIQ)

On the accommodation side of the property industry, the Australian Resident Accommodation Managers Association (ARAMA) has highlighted the pace of legislative change as a standing pressure point for resident managers. As ARAMA put it in a 2024 note to members: “ARAMA exists to represent the industry in a way that our members can’t.” The association added: “There has been a lot of reform in the last few years and we have spent a lot of time working on new laws to safeguard MLR businesses.” While not an AML-specific statement, it captures the stakeholder fatigue many operators feel as overlapping state and federal changes roll through. (Arama)

One important nuance from the federal consultations: property management and leasing were removed from the scope of proposed AML regulation during 2024, a shift welcomed by the Property Council because those transactions were seen as high-volume, lower-risk compared with sales. That tweak, if maintained in the final Rules for tranche 2, narrows the immediate impact on managers while keeping the focus on sale and purchase risks. (Property Council Australia)

Timeline at a glance

  • October 2025: AUSTRAC to publish core guidance to help new entrants design programs and understand obligations. (AUSTRAC)
  • 31 March 2026: Enrolment opens for newly regulated “tranche 2” businesses, including real estate professionals. (AUSTRAC)
  • 1 July 2026: Obligations commence for real estate designated services; agencies must be enrolled and operationally compliant. (AUSTRAC)

What agencies should do now

Even before the October guidance lands, AUSTRAC’s materials allow a clear head-start:

  1. Decide if you’re in scope. Use AUSTRAC’s “am I regulated?” checker and review the new industries page to confirm which of your services (e.g., sales vs property management) are covered. (AUSTRAC)
  2. Map your risks. Draft a ML/TF/PF risk assessment tailored to your agency’s services, client base, geographies and deal structures. This drives the shape of your AML/CTF program. (AUSTRAC)
  3. Design your AML/CTF program. Document policies for customer due diligencebeneficial ownershipsanctions and PEP screeningongoing monitoringsuspicious matter reportingrecord-keeping and training. Assign a compliance officer and plan for an independent review at least every three years. (AUSTRAC)
  4. Pick your tools. Consider regtech solutions for client verification, sanctions/PEP checks and transaction monitoring—especially if you have multiple offices or higher-risk segments. (AUSTRAC maintains guidance for third-party reliance and outsourcing.) (AUSTRAC)
  5. Budget realistically. While small agencies are unlikely to pay AUSTRAC’s industry contribution levy, you’ll still need to budget for training, systems and periodic reviews. Larger diversified property groups should factor potential levy invoices into FY27 planning. (AUSTRAC)

Why it matters

International watchdogs have long flagged real estate as a money-laundering risk because high-value assets can be used to store and cleanse illicit funds. The government’s reform package—backed by the $167.8 million Budget allocation and AUSTRAC’s staged rollout—is designed to close those gaps while keeping compliance risk-based and proportionate. For most agencies, the heavy lift will be organisational: writing a fit-for-purpose program, training staff and embedding checks at the points of listing, offer, and settlement. (Grant Thornton AustraliaAUSTRAC)

The message from regulators is consistent: don’t wait. With guidance due in October and enrolments opening next March, agencies that start now—by scoping risk, drafting policies and trialling verification workflows—will hit July 2026 with fewer surprises, fewer delays at the coalface, and a better chance of keeping compliance costs in check.


Sources: AUSTRAC reform pages, timelines and obligations; REIQ media release (5 Nov 2024); ARAMA member communication (1 Aug 2024); federal Budget commentary and AUSTRAC levy guidance. (AUSTRACGrant Thornton AustraliaREIQAramaProperty Council Australia)

Author: The Onsite Manager

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