Sanctions screening for Real estate agents — 2026 AUSTRAC Guide

From 1 July 2026, a real estate business that provides a designated service must screen its customers against the DFAT autonomous sanctions list and the UN Security Council consolidated list before acting for them and during the relationship. This matters in property work because sanctioned people may try to buy, sell or move value through real estate using agents, buyer’s agents or related entities. If you deal with a sanctioned person, you can expose your business and staff to strict-liability criminal consequences, and wider AML/CTF breaches can carry civil penalties of up to $33.5 million per contravention.

Your AML/CTF obligations

For a real estate agent, sanctions screening is not just checking ID at appraisal or before exchange. It means checking whether the person or entity you are acting for appears on Australia’s sanctions lists, and repeating that check while you continue to act for them. In practice, that can include a vendor, purchaser, buyer’s agent client, company purchaser, trustee, or anyone behind the customer who owns 25% or more or exercises effective control. If your customer is a company or trust, screening only the front name is not enough.

How a real estate agency should handle it

Build screening into onboarding before you provide the designated service, not after a contract is signed or deposit is paid.
Collect the correct names, dates of birth and addresses for individuals, and the legal name, ABN or ACN, trustees and beneficial owners for companies and trusts.
Screen the customer and relevant beneficial owners against the DFAT autonomous sanctions list and the UN Security Council consolidated list.
If you get a possible match, stop and review it properly before progressing the matter. Do not assume a similar name is harmless and do not continue with the transaction until resolved.
Re-screen during the relationship, especially if the matter runs for months, the ownership structure changes, or a new controller appears.

Property transactions can change mid-matter

Real estate files often evolve after the first contact. A purchase may switch from an individual to a company, a trust may be inserted, a family member may fund the deal, or an overseas controller may appear late. Each change is a trigger to refresh your customer due diligence and sanctions screening.

The most common mistakes in real estate are practical ones. Agencies often screen the person attending the inspection but not the actual buying entity, or they rely on a conveyancer or lawyer to do it. Your AML/CTF obligation is federal and sits with your business if you provide the designated service. Another mistake is treating sanctions screening as a one-off database check. Long settlement periods, off-the-plan sales, developer stock, and buyer representation work all create time for list changes or customer changes, so ongoing screening matters.

Practical tips for principals and sales teams

Add a sanctions check step to your listing authority and buyer onboarding workflow.
Use the exact legal name on the contract, company search or trust documents when screening, not just a trading name or nickname.
Have a clear escalation rule: sales staff stop the file and refer any match or near-match to the principal or nominated AML/CTF lead.
Keep evidence of the screening result and date on the property file, then retain it for 7 years after the relationship ends.
Train reception, sales agents and admin staff because they often collect the first customer information and can miss changes in ownership or control.

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Frequently asked questions

Do I need to screen both the seller and the buyer?

If you provide a designated service to them, yes. In real estate practice that can mean screening the vendor client, the purchaser client, or both, depending on who your agency is acting for. The key question is who your customer is for the designated service, not just who attends the open home.

Can I rely on the buyer's lawyer or conveyancer to do sanctions screening for me?

No. Another adviser may do their own checks, but that does not replace your agency’s obligation if your business is the reporting entity providing the designated service. You should have your own process, records and escalation steps.

What if the purchaser is a company or a trust?

You need to look past the entity name. Verify the company or trust details, identify the trustees and beneficial owners, and screen the people who ultimately own 25% or more or exercise effective control. Screening only the company name on the contract is not enough.

What happens if the screening shows a possible match?

Pause the matter and review the match carefully using the customer’s identifying details. Do not keep progressing the sale or lease-related transaction while you assume it will be fine. If the circumstances give you reasonable grounds to suspect something is wrong, you may also need to consider a suspicious matter report and you must not tip off the customer.

Is sanctions screening expensive, and do I need special software?

The law requires screening, but it does not say you must buy one particular product. A small agency can start with a documented process that fits its size and transaction volume, provided it screens before and during the relationship and keeps proper records. If you handle many matters, company purchasers or overseas-linked clients, software may be the more reliable option.

Sanctions screening for Real estate agents — 2026 AUSTRAC Guide

Frequently asked questions

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