Australia’s property industry has operated largely outside the federal anti-money laundering framework since 2006. That changes on 1 July 2026.
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 brings real estate agents, buyer’s agents, conveyancers, accountants, lawyers, and property developers into the regulatory net for the first time. These are the so-called “Tranche 2” reforms — long anticipated, now here — and they have direct, practical implications for anyone buying, selling, or investing in Australian property.
At Thornwick, we think clarity is more useful than alarm. Here is what you need to know.
Real estate has long been identified — domestically and by the global financial crime watchdog, the Financial Action Task Force (FATF) — as one of the highest-risk channels for money laundering. A single property transaction can move a significant sum in one hit, making it attractive to those seeking to legitimise illicit funds. Australia has been one of the last developed countries to regulate the professions that facilitate those transactions.
The Amendment Act 2024 closes that gap. From 1 July 2026, real estate professionals who broker the sale, purchase or transfer of property must comply with AUSTRAC’s anti-money laundering and counter-terrorism financing (AML/CTF) obligations.
For real estate agencies like Thornwick, the obligations are substantive. They include:
Enrolment with AUSTRAC All agencies providing a designated service must enrol with AUSTRAC. Enrolment opened on 31 March 2026, with a deadline of 29 July 2026 for newly regulated entities.
Customer Due Diligence (CDD) Agencies must verify the identity of both buyers and sellers — not just one party. AUSTRAC considers a selling agent to owe obligations to both the buyer and the seller in a standard transaction. This means collecting and verifying identification, understanding the purpose of the transaction, and assessing risk before the service is provided.
AML/CTF Program Every reporting entity must have a written AML/CTF program in place. This is a two-part document: Part A covers how the agency identifies and manages money laundering and terrorism financing risks in its operations; Part B covers the customer identification and verification procedures, including screening for politically exposed persons (PEPs).
Suspicious Matter Reports (SMRs) Where a transaction raises a reasonable suspicion of money laundering or terrorism financing, agencies must lodge a Suspicious Matter Report with AUSTRAC — within three business days, or 24 hours where terrorism financing is suspected. There is no minimum dollar threshold.
Threshold Transaction Reports (TTRs) Cash transactions of $10,000 or more must be reported to AUSTRAC within ten business days.
Seven-Year Record-Keeping Transaction records, customer identification documents, and AML/CTF program documents must be retained for seven years and produced to AUSTRAC on request.
An AML/CTF Compliance Officer Agencies must appoint a compliance officer at management level who is responsible for overseeing the program and ensuring ongoing compliance.
If you are transacting on property from 1 July 2026, expect a more thorough identity verification process at the beginning of your engagement with any licensed agent. This is not unique to Thornwick — it is a legal requirement across the industry.
You will be asked to provide identification. Depending on the nature of the transaction, the agent may also ask questions about the source of funds or the purpose of the acquisition. These are not invasive questions out of curiosity; they are obligations imposed by federal law.
The tipping-off rules also apply: your agent cannot disclose to you that a suspicious matter report has been lodged in relation to your transaction. This is a federal offence under the reformed AML/CTF Act.
Property investors — particularly those transacting frequently, using complex ownership structures, or acquiring through SMSF or trust arrangements — should expect more detailed onboarding. Agents are now required to understand not just who you are, but the structure through which you’re acquiring, and the beneficial owners behind it.
AUSTRAC specifically calls out politically exposed persons, complex ownership arrangements, and unusual payment patterns as areas requiring enhanced scrutiny. If you’re investing through a corporate trustee, a company, or a foreign-controlled structure, you should be prepared to provide documentation that goes beyond a standard ID check.
This is not a barrier to investing. It is a baseline transparency expectation that brings Australian property into line with how financial institutions have operated for two decades.
We enrolled with AUSTRAC ahead of schedule. Our AML/CTF program is in place, our compliance officer appointed, and our team trained on the new obligations.
What that means in practice: every new client engagement will include a formal identity verification process and an upfront risk assessment. This will feel like a modest additional step at the beginning of a transaction. It is.
We do not treat compliance as a bureaucratic inconvenience. The reforms exist because property has been used to launder money — and that distorts prices, harms genuine buyers, and undermines the integrity of the market we work in every day. We are for that not happening.
If you have questions about what to expect when engaging Thornwick, or what documents you should bring to a first meeting, speak to us directly.
This article is for general information only and does not constitute legal advice. For advice specific to your circumstances, please consult a qualified legal practitioner.
Thornwick is a licensed real estate agency operating in Melbourne’s inner, northern, and western suburbs. Learn more at thornwick.com.au
Melbourne's inner, northern & western suburbs.
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