Guide
AML/CTF Tranche 2 for Australian real estate agents
Since 1 July 2026, Australian real estate agencies have AML/CTF obligations. What a sole trader or small agency has to do, from AUSTRAC's own guidance.
The short answer
Australian real estate agencies took on AML/CTF obligations on 1 July 2026, with enrolment with AUSTRAC due by 29 July 2026. Each agency needs a money laundering and terrorism financing risk assessment, AML/CTF policies, customer due diligence, and records that show it complies.
A sole trader can hold all three governance roles: governing body, senior manager and AML/CTF compliance officer. AUSTRAC says they do not need to report to themselves, but they remain responsible for each role's duties.
- Governance for a sole trader
- Often one person acts in all three roles. You can outsource governance roles, including the compliance officer, if eligibility requirements are met, and you stay responsible for your obligations.
- Customer due diligence
- AUSTRAC publishes guides for checking individual and sole-trader customers.
- Independent evaluation
- At least every three years, by an evaluator who is independent and suitable. First deadlines are staggered under the AML/CTF Transitional Rules 2026, and you must document why you chose your frequency.
Questions agents ask
When did Tranche 2 start for real estate agents?
Obligations commenced on 1 July 2026. Agencies had to enrol with AUSTRAC by 29 July 2026.
Can a sole trader be their own AML/CTF compliance officer?
Yes. AUSTRAC says a single person often acts as governing body, senior manager and compliance officer, and remains responsible for each role's duties.
Can I outsource my AML/CTF compliance?
You can outsource governance roles if eligibility requirements are met, but AUSTRAC says you are still responsible for meeting your obligations.
How often is an independent evaluation needed?
At least every three years, by an independent and suitable evaluator. First deadlines are staggered under the Transitional Rules 2026.
Your programme, files and evidence in one record
Indium runs the fourteen-stage due diligence path and keeps the records AUSTRAC expects to see.
Sources
General information, not legal advice. Checked against the sources above in October 2026. Rules change, so confirm with your regulator. More guides.
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