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AML/CTF program for Real estate agents — 2026 AUSTRAC Guide

From 1 July 2026, a real estate business that provides a designated service becomes a reporting entity and must have a written AML/CTF program. For real estate agents, this program is the document that shows how you will identify and manage money laundering, terrorism financing and proliferation financing risks in property sales, purchases and transfers. If you do not put one in place by 31 December 2026, AUSTRAC can take enforcement action, with civil penalties of up to $33.5 million per contravention and criminal penalties for intentional breaches.

Your AML/CTF obligations

  1. 1. AUSTRAC enrolment
  2. 2. Compliance officer
  3. 3. ML/TF risk assessment
  4. 4. AML/CTF program
  5. 5. Customer due diligence
  6. 6. Sanctions screening
  7. 7. Suspicious matter reporting
  8. 8. Record keeping (7 years)
  9. 9. Staff training

Your AML/CTF program is not a template you file once and forget. It is a written, senior-management-approved system for how your agency will handle risky property work. It has 2 parts: first, your ML/TF risk assessment, which identifies and rates the risks in your customer base, services, delivery channels and geographic exposure; second, your AML/CTF policies, which set out the procedures, systems and controls your agency will use to manage those risks. For a real estate agency, that usually means covering residential and commercial transactions, buyer-side work, remote onboarding, trust-related ownership structures, foreign-linked purchasers, cash deposits, and unusual settlement arrangements.

Deadline and approval

Your AML/CTF program must be finalised by 31 December 2026. It must be in writing and approved by senior management. You also need to complete the ML/TF risk assessment before you finalise the program.

What a real estate agency should do step by step

  • Confirm whether the services you provide are designated services. Not every activity in a real estate office will be captured, so check the service, not just your job title.
  • Write a risk assessment that reflects how your agency actually operates: vendor sales, buyer's agency work, auction campaigns, off-market transactions, commercial property, interstate or overseas clients, and entity buyers such as companies and trusts.
  • Set practical policies for customer due diligence before you provide the designated service, including how staff verify individuals, companies, trusts and beneficial owners.
  • Build sanctions screening into onboarding and ongoing client management, using the DFAT autonomous sanctions list and the UN Security Council consolidated list.
  • Set internal reporting rules for suspicious matter reporting, record keeping for 7 years after the relationship ends, and staff training for agents, property sales staff, trust account staff and admin teams who handle relevant transactions.
  • Have senior management approve the final program, keep version control, and update it whenever your business changes materially, such as adding buyer's agency services, opening in a new region or taking on more offshore clients.

A common mistake in real estate is assuming enrolment with AUSTRAC is the program. It is not. Enrolment is a free notification done through AUSTRAC Online, while the AML/CTF program is the written framework that explains how your office will comply day to day. Another mistake is copying a generic policy that says nothing about how property deals actually happen in your agency. AUSTRAC has sector guidance and a program starter kit for real estate professionals, and those resources are far more useful than a one-size-fits-all manual that ignores auctions, deposits, nominee purchasers, vendor instructions, and trust or company ownership.

Practical tips for real estate offices

  • Map your sales workflow from listing to settlement and identify where AML checks fit without slowing every transaction.
  • Give agents a clear escalation path for red flags such as buyers who avoid identification, use complex ownership structures without a commercial reason, or want to split physical cash payments.
  • Separate low-risk and high-risk files so enhanced due diligence is applied where needed, including for PEPs, high-risk countries and unusual funding patterns.
  • Make sure trust account staff and sales staff are working from the same procedures so deposits, refunds and changes to payer details are picked up early.
  • Train reception and admin staff as well as agents, because they often collect IDs, receive documents and hear explanations that do not make sense.

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Frequently asked questions

Do I need an AML/CTF program if I only sell residential homes in one suburb?
If you provide a designated service, yes. A smaller suburban agency may have a simpler program than a commercial or cross-border practice, but it still needs a written ML/TF risk assessment and written policies tailored to how your office handles property transactions.
Can I just buy a template program and use it as is?
Not safely. A template can be a starting point, especially if it is built for real estate, but your program must reflect your actual services, customers, delivery channels and geographic risks. If it does not match how your agency operates, it will not work in practice and may not satisfy AUSTRAC expectations.
What if my agency uses companies or trusts as buyers all the time?
Your program needs specific procedures for entity customers. That includes verifying company details through ASIC, obtaining trustee and trust deed information for trusts, and identifying beneficial owners who hold 25% or more or otherwise exercise effective control.
Does the AML/CTF program have to be finished before 1 July 2026?
No. Tranche 2 obligations start on 1 July 2026, and the AML/CTF program must be finalised by 31 December 2026. But you should start earlier, because you need the ML/TF risk assessment first and your staff will need workable procedures during the second half of 2026.
How much will this cost a small agency, and can I do it myself?
AUSTRAC enrolment is free, but building the program will still take time and resources. Many small agencies can do much of the work themselves using AUSTRAC guidance and the real estate starter kit, provided the final program is specific to their business and senior management approves it.

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