Which real estate services are covered?
The work you do determines coverage. A job title, property value or cash payment alone does not decide it.
Brokering a transaction
Brokering the sale, purchase or transfer of real estate in the course of business is covered by table 5, item 1. This includes buyer and seller agency work. A transfer can be covered even without payment.
Selling without an independent agent
Selling or transferring real estate in the course of a business selling real estate, without an independent real estate agent brokering it, is covered by table 5, item 2. Property developers selling directly can fall here.
Check the boundaries
Ordinary rental management alone is generally outside these real estate services. Check the actual activity and interest in land: the definition includes some ownership-like leases longer than 30 years. Incidental business sales and private residential sales are not automatically covered.
One transaction. Different customer relationships.
Use the designated service to decide whose information you need. This map shows customer scope, not permission to delay checks.
Agent brokering the sale
Both buyer and seller are customers for the brokering service, even when the agency acts for only one side. Include representatives, authority and relevant beneficial owners in your checks.
Developer selling directly
For the business sale without an independent broker, the customer is the buyer or transferee. Do not copy the two-party brokering rule into every property service.
When your service starts
For a seller agent, the service to the seller starts when the agency agreement is signed. The service to the buyer generally starts when the transaction is reasonably expected to proceed, typically when the offer is accepted and the contract signed. Buyer agency work follows the corresponding rule for each side.
Why is real estate a money laundering target?
High-value property can be used to store or move criminal proceeds. Look at the transaction, ownership and funding together. A risk indicator is a reason to investigate, not proof of wrongdoing.
Ownership that is hard to explain
Unnecessarily complex companies, trusts or nominee arrangements can obscure who benefits. Ask what the structure does and identify who ultimately owns or controls the customer.
Funding that does not fit
Unexpected third-party payments, unexplained funding or a purchase inconsistent with known circumstances warrant further enquiries. Record the explanation and evidence, then assess the risk.
An unusual transaction pattern
Rapid resales, unusual pricing or pressure to avoid normal checks may need escalation. Consider the surrounding facts before deciding whether an SMR obligation arises.
Build checks into the agency workflow
Enrol and assign responsibility
Businesses already providing newly regulated services had to enrol by 29 July 2026. A new provider generally applies within 28 days after the day it starts providing a designated service. Appoint an eligible compliance officer, record their authority and notify AUSTRAC within the applicable period.
Put your program into practice
Before providing designated services, establish an AML/CTF program that addresses your risks. Document your risk assessment and policies, obtain senior manager approval, train staff and set review and independent evaluation arrangements. Templates need to be customised and used in daily work.
Complete customer due diligence
Generally complete initial CDD before providing the designated service. Establish identity, relevant beneficial ownership, authority, purpose and risk, including applicable PEP and sanctions checks. Delayed CDD is conditional, including where an auction makes immediate checks impracticable. Check the precise conditions before relying on it.
Make the handover explicit
Give staff a clear place to record checks, missing information and escalation decisions. Explain checks early to customers, agree who reviews exceptions and monitor the relationship for changes. Build time into listings, agency appointments and settlement preparation.
Know when a report is required
SMR: suspicion, not a dollar threshold
Where the SMR obligation arises, report terrorism financing suspicions within 24 hours of forming the suspicion. For other suspicions, report within 3 business days after the day the suspicion forms. Special legal professional privilege rules can apply; check the SMR guide. An unusual transaction alone does not establish reasonable grounds for suspicion.
TTR: a physical currency payment
Report a physical currency transaction of AUD $10,000 or more (or its foreign currency equivalent) made in connection with a designated service within 10 business days after the day it occurs. Card payments, bank transfers and virtual assets are not physical currency. Do not add separate instalments together to create a TTR threshold.
Keep the record of what happened
Record checks, decisions, monitoring and reports under the applicable retention rules. Keep required identity information and verification records; the law does not require retaining copies of identity documents. AML Mate prepares report records and does not submit reports to AUSTRAC. Lodge in AUSTRAC Online and keep your receipt and reference.
Make the process workable for your agency
Start with existing work
Map your current intake, identity checks and transaction records to the requirements. Close the gaps and train everyone who handles enquiries, listings or payments. There is no reliable universal number of minutes per customer: complex structures and higher-risk matters need more work.
Choose support for the gaps
Budget for staff time, verification, training, reviews and any external advice you need. AML Mate can help organise your program, client checks and report records. Your business remains responsible for its decisions and obligations.
Frequently asked questions
Do real estate agents need AML/CTF compliance?
Yes, when they provide a designated real estate service with a geographical link to Australia. The new obligations started on 1 July 2026. Check the service definition and exclusions rather than relying on the agency job title.
What AML obligations do real estate agents have?
Covered businesses must enrol, implement an AML/CTF program, appoint an eligible compliance officer, conduct customer due diligence, monitor, report when required and keep records. For brokering under table 5, item 1, both buyer and seller are customers.
Do property managers need AML compliance?
Ordinary rental management alone is generally not a real estate designated service. Brokering sales or transfers, and other designated services, need a separate assessment. Check the interest in land and the actual activity.
What are red flags for money laundering in real estate?
Examples include unexplained third-party funds, unnecessarily complex ownership, unusual pricing, rapid resales and reluctance to provide information. Assess the context and record enquiries; an indicator alone does not prove money laundering.
Resources and sources
Official guidance checked on 14 October 2026. Follow the source for the full conditions and exceptions.