A property deal can look perfectly ordinary on the surface: a buyer makes an offer, the seller accepts, the lawyers handle the paperwork and everyone moves towards settlement. But what happens when funds arrive from an unexpected third party, the ownership structure becomes unusually complex, or the buyer is reluctant to explain who is really behind the transaction?
Those are exactly the kinds of situations Australia’s expanded anti-money laundering regime is designed to make businesses examine more carefully.
Since 1 July 2026, certain services provided by real estate businesses, lawyers, conveyancers, accountants and other professional service providers have fallen within Australia’s expanded AML/CTF framework. For affected businesses, Tranche 2 is no longer something sitting on the compliance calendar—it is part of the regulatory environment they operate in today.
The important distinction is that regulation does not simply depend on your job title. Whether a business has AML/CTF obligations depends largely on the designated services it provides.
If you need the bigger picture first, our complete guide to anti-money laundering in Australia explains the wider framework. Here, we are narrowing the focus to property transactions—who can be affected by Tranche 2 and what compliance can look like for real estate agents, lawyers, conveyancers and accountants.
What Does AML Tranche 2 Mean for Australian Real Estate?
AML Tranche 2 expanded Australia’s anti-money laundering and counter-terrorism financing regime to cover additional designated services.
For the property sector, the key point is simple: the rules apply to particular services, not automatically to everyone with a particular professional title.
A real estate business may have AML/CTF obligations when it provides a designated service involving the brokering of a sale, purchase or transfer of real estate. AUSTRAC identifies buyer’s agents, seller’s agents and certain property developers among businesses that can fall within these rules. Its guidance on real estate designated services explains the scope in more detail.
The same transaction may also involve lawyers, conveyancers or accountants providing a separate category of professional designated service.
Once a business provides a relevant designated service, its responsibilities can extend beyond checking identification. Depending on the circumstances, the business may need an AML/CTF program, customer due diligence processes, risk controls, reporting procedures, appropriate records and trained staff.
For a broader explanation of these requirements, see our guide to AML/CTF compliance obligations for Australian businesses.
Who Does Tranche 2 Cover in a Property Transaction?
Tranche 2 does not place everyone working in property, law or accounting into the same compliance bucket. The important question is what service is actually being provided.
Real Estate Agents and Buyer’s Agents
Real estate agents can be regulated when they provide designated services involving the brokering of a sale, purchase or transfer of real estate.
That can include seller’s agents and buyer’s agents. Businesses therefore need to consider their actual activities rather than assume every service offered by an agency is either automatically included or excluded.
AUSTRAC’s real estate designated services guidance also explains when a seller’s or buyer’s agent starts providing the relevant designated service.
Property Developers
Property developers can also fall within the regime in certain circumstances.
AUSTRAC identifies businesses selling house-and-land packages, off-the-plan apartments or subdivided land without an independent real estate agent as examples that may provide a designated service.
Again, being a developer is not the test by itself. What matters is how the property is being sold or transferred and whether the activity meets the designated-service definition.
Lawyers and Conveyancers
Lawyers and conveyancers involved in property transactions can be regulated through professional designated services.
This can include certain work that helps plan or execute the sale, purchase or transfer of property, such as preparing transaction documents, progressing conveyancing work or acting for a client during the transfer.
AUSTRAC’s professional designated services guidance focuses on the activity being performed rather than the professional title of the person carrying it out.
Accountants and Other Professional Advisers
The same principle applies to accountants.
An accountant does not automatically fall under Tranche 2 because a client happens to be buying or selling property. AML/CTF obligations may arise, however, where the accountant provides a relevant designated professional service connected with transactions, assets, companies, trusts or other regulated arrangements.
AUSTRAC distinguishes between activity that merely influences a transaction and activity sufficiently connected to planning, executing or directly advancing it. Businesses therefore need to assess their actual service offering rather than rely on assumptions about their profession.
How AML Obligations Can Apply Across One Property Transaction
One property transaction can involve several regulated businesses at the same time.
Imagine a buyer purchasing a residential property through a buyer’s agent. The seller has their own agent, both parties engage lawyers or conveyancers, and the buyer also receives accounting advice about an ownership structure.
The seller’s agent may be providing a designated service by brokering the sale. The buyer’s agent may be brokering the purchase. A lawyer or conveyancer may provide a professional designated service connected with executing the transfer. An accountant may also come within the regime if their work meets one of the relevant designated-service definitions.
In simplified form, the transaction might look like this:
Seller → Seller’s Agent → Buyer → Buyer’s Agent → Lawyer or Conveyancer → Settlement
Accountants and other advisers may sit alongside that process depending on how the deal is structured.
The key point is that each regulated business needs to understand its own AML/CTF responsibilities. The presence of another professional in the transaction does not automatically mean AML obligations have been “taken care of” elsewhere.
What AML/CTF Obligations Do Real Estate Businesses Need to Meet?
Once a business determines that it provides a designated service, AML/CTF compliance becomes an operational responsibility.
Enrol With AUSTRAC
Businesses covered by the regime need to understand their AUSTRAC enrolment obligations and ensure relevant information remains current.
For newly regulated businesses, this should already be part of the compliance framework rather than a future project.
Assess ML/TF/PF Risks
A regulated business needs to understand how its services could be exposed to money laundering, terrorism financing or proliferation financing risks.
Relevant factors can include the customers it serves, transaction characteristics, geographic exposure, delivery channels and the designated services being provided.
A risk-based approach does not mean treating every customer as suspicious. It means applying controls that reflect the level and nature of the risk.
Maintain an AML/CTF Program
An AML/CTF program should translate identified risks into practical policies, procedures and controls.
For a property business, that means connecting compliance with real workflows—customer onboarding, transaction progression, escalation, reporting and decision-making.
Responsibilities should also be clear, including the role of the AML/CTF compliance officer.
Carry Out Customer Due Diligence
Customer due diligence, or CDD, involves establishing who the customer is, verifying relevant information and assessing the risk associated with the relationship.
Depending on the circumstances, this may also involve identifying beneficial owners or obtaining additional information where risk is higher.
A straightforward transaction involving an individual buyer can create different risk considerations from a high-value transaction involving companies, trusts, overseas parties or complicated funding arrangements.
CDD is therefore more than collecting identification documents. It helps the business understand who it is dealing with and the risk presented by the relationship and transaction.
Monitor Risk and Apply Enhanced Due Diligence Where Required
Risk can change after onboarding.
Changes to ownership structures, funding arrangements, customer behaviour or transaction instructions may require further attention. Businesses need processes for ongoing due diligence and enhanced measures where the circumstances require them.
Report Relevant Matters to AUSTRAC
Reporting entities may also need to lodge reports with AUSTRAC, including Suspicious Matter Reports where the relevant legal threshold is met.
Because reporting requirements are specific, businesses need to understand which reports apply to them and when. Our guide to AUSTRAC reporting requirements for Australian reporting entities covers this area in greater detail.
Keep Appropriate Records
AML/CTF compliance also needs to be documented.
Relevant records may include customer identification and verification information, CDD documentation, risk assessments, transaction records, AML/CTF program records and evidence of staff training.
AML Red Flags in Real Estate Transactions
Most property transactions are legitimate, and a red flag does not prove that money laundering or another financial crime is taking place.
It does, however, indicate that something may deserve closer examination under the business’s risk-based AML/CTF procedures.
Potential red flags can include:
- a customer reluctant to provide identification or beneficial ownership information;
- funds coming from an unexpected third party or jurisdiction;
- unnecessarily complex company or trust structures;
- sudden changes to buyers, ownership structures or payment arrangements;
- transactions inconsistent with what is known about the customer;
- unusual urgency without an obvious commercial explanation;
- high-value purchases involving unusual financing arrangements; or
- a purchaser showing little interest in the property itself while focusing heavily on moving funds.
For lawyers, conveyancers and accountants, concerns may also arise when transaction structures become unnecessarily complicated, instructions change without explanation or a professional is asked to handle funds in a way that does not fit the stated purpose of the matter.
AUSTRAC’s guidance on money laundering and terrorism financing risks in newly regulated sectors provides further examples of sector-specific risk indicators.
Context matters. A single unusual feature can have an innocent explanation. Multiple indicators appearing together may justify additional due diligence, escalation or further consideration under the organisation’s AML/CTF procedures.
What Should Real Estate and Professional Services Firms Have in Place Now?
Now that Tranche 2 is in force, affected businesses need to make sure compliance is reflected in day-to-day operations.
That starts with understanding which services are designated services and where they appear in the customer journey. AUSTRAC’s guidance for newly regulated entities provides a useful starting point.
Risk assessments should connect with actual workflows. Customer onboarding, identity verification, beneficial ownership checks, escalation procedures and record keeping should operate as part of the way work is performed.
Responsibility also needs to be clear. Employees should know who the AML/CTF compliance officer is, when a concern should be escalated and how relevant decisions are documented.
Processes also need to deal with changes during a transaction—for example, where a trust or company is introduced, ownership changes, funding arrangements shift or information conflicts with what was originally provided.
A written AML/CTF program is important, but it only works if the people responsible for applying it understand what it means in practice.
Why AML/CTF Training Matters for Real Estate Teams
AML/CTF controls can break down quickly when employees know a policy exists but do not understand how it applies to the transaction in front of them.
Relevant staff should understand how customer due diligence works, what risk indicators to recognise, how the organisation’s procedures apply to their role and when something needs to be escalated.
That matters because unusual activity can appear at different stages of a property deal. An agent may identify a concern during customer onboarding, while a lawyer, conveyancer or accountant may notice something later when reviewing ownership structures, funds or transaction instructions.
For organisations building or refreshing that knowledge, our Anti-Money Laundering and Counter-Terrorism Financing training helps Australian workplaces understand core AML/CTF principles, risk indicators and compliance responsibilities.
Training does not replace an AML/CTF program or risk assessment. It helps employees apply those controls consistently.
