Is My Real Estate Agency Affected by AUSTRAC Tranche 2?

Of all the industries affected by AUSTRAC Tranche 2, real estate is one of the most widely impacted — and one of the least prepared. Most agency principals we speak to are either unaware of their obligations or assume the changes don't apply to them.

The reality is almost every real estate agency in Australia that actively assists with property transactions is in scope. And the deadline is 1 July 2026.

Why Real Estate Agencies Are in Scope

Property has long been identified by AUSTRAC and international regulators as a high-risk channel for money laundering. Large transactions, complex ownership structures, and offshore buyers create significant financial crime risk that the current framework doesn't adequately address.

Tranche 2 closes that gap by bringing real estate professionals directly into the AML/CTF regulatory framework for the first time.

Which Real Estate Businesses Are Captured?

The obligation applies based on your services, not your licence type. You are in scope if you:

Assist clients with buying or selling residential or commercial property
Act as a buyers agent or buyers advocate
Manage property on behalf of clients where funds are handled
Assist with property development sales
Handle trust accounts or client deposits in connection with transactions

Important: Even if your agency only occasionally assists with transactions — or does so as part of a broader service — you may still be captured. Infrequent or low-volume designated services are not exempt.

What Do Real Estate Agencies Need to Prepare?

A risk assessment covering your client types, property markets and transaction patterns
A written AML/CTF Program tailored to your agency
Customer Due Diligence — verifying buyer and seller identity before transactions
Enhanced due diligence for high-risk clients including overseas buyers
A Suspicious Matter Reporting process for your staff
Staff training across all agents involved in transactions
AUSTRAC enrolment before 29 July 2026

The Timeline Is Tight

With the deadline approaching, agencies that haven't started are already behind. Building an AML/CTF program, training staff and enrolling with AUSTRAC takes time — particularly when your team is focused on listings, auctions and client relationships.

The agencies that navigate this best will be the ones who outsource the compliance build to an expert and focus their energy on their business.

Civil penalties up to $33.5M per breach for non-compliance. AUSTRAC publishes enforcement actions publicly — your professional body and clients can see them.

How Stratos AI Helps Real Estate Agencies

Stratos AI specialises in helping Perth and Australian real estate agencies get AUSTRAC-ready quickly. We build your complete AML/CTF program, customised to your agency's client profile and transaction types — reviewed by a CPA with 30+ years of business experience. $2,500, all-inclusive, delivered before 1 July.