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AUSTRAC Tranche 2

The Plain-English Guide to AUSTRAC Tranche 2

From 1 July 2026, businesses that provide newly regulated designated services have AML/CTF obligations. This guide focuses on Australian real estate agencies, buyer’s agents and other businesses that provide real-estate designated services.

What is Tranche 2?

“Tranche 2” is the second stage of Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime. It extends the AML/CTF Act 2006 to certain services provided by real estate professionals and other newly regulated businesses.

The reforms were enacted by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024, which received Royal Assent on 10 December 2024. New tranche 2 entities must comply from 1 July 2026.

Who does this guide cover?

You may be a reporting entity if your real estate business provides one of the designated services below:

  • Real estate agents and buyer’s agents - brokering the sale, purchase or transfer of real estate.
  • Property developers - selling or transferring real estate as part of a business selling real estate, including off-the-plan sales.

AUSTRAC’s real-estate guidance sets out the designated services and when they begin. Whether a particular activity is captured depends on the service provided, so check the current guidance for your circumstances.

Key dates

  1. 10 December 2024
    Royal Assent
    The AML/CTF Amendment Act 2024 became law.
  2. 31 March 2026
    Changes commence for existing reporting entities
    Reforms apply to entities already regulated by AUSTRAC.
  3. 1 July 2026
    Tranche 2 obligations commence
    Newly regulated real estate businesses need to meet their AML/CTF obligations when providing designated services.
  4. 29 July 2026
    Transition enrolment date (completed)
    AUSTRAC set this as the transition enrolment date for newly regulated businesses that began providing designated services from 1 July 2026. The general rule remains: apply to enrol within 28 days of starting a designated service — check current AUSTRAC guidance for your circumstances.

(Source: AUSTRAC, “Enrol now and meet your obligations”, accessed 10 July 2026)

Your five core obligations

The work is practical and ongoing. These are the main areas to organise for a real estate business providing designated services.

  1. Obligation 01
    Enrol with AUSTRAC

    Register your business through AUSTRAC Online. AUSTRAC set 29 July 2026 as the transition enrolment date for newly regulated businesses that began providing designated services from 1 July 2026; the general enrolment rule is within 28 days of starting a designated service — check current AUSTRAC guidance for your circumstances.

  2. Obligation 02
    Have an AML/CTF program

    Have a documented AML/CTF program appropriate to your business before providing designated services. It should cover your risk assessment, controls, governance and staff training, with an AML/CTF Compliance Officer in place.

  3. Obligation 03
    Customer due diligence (CDD)

    Identify and verify customers and beneficial owners, understand the nature and purpose of the relationship, and use enhanced checks where the risk calls for them.

  4. Obligation 04
    Ongoing monitoring and reporting

    Monitor the relationship and report suspicious matters. Submit a Suspicious Matter Report (SMR) within 24 hours for terrorism-financing suspicions, or within 3 business days for other suspicions. Do not tip off the customer.

  5. Obligation 05
    Record-keeping

    Keep accurate records of customer identification, risk assessments, transactions and AML/CTF program decisions. Most relevant records have a 7-year retention period, but the exact requirement depends on the record type.

What AUSTRAC expects after 1 July

AUSTRAC says newly regulated businesses should be enrolled, have an AML/CTF program and Compliance Officer, train their staff, and be ready to report suspicious matters.

AUSTRAC’s starter kit is designed as a practical starting point. You must assess whether it suits your business and adapt it where needed.

60-second readiness checklist

Use this as a prompt for a proper review of your business. It is not a legal or compliance assessment.

Organise your AML/CTF workflow

AMLHive helps real estate teams structure their evidence, tasks and review workflow. It does not submit reports or replace professional advice.

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Frequently asked questions

Does Tranche 2 apply to property managers?

Whether a particular activity is captured depends on whether it is a designated service. AUSTRAC's real-estate guidance covers brokering the sale, purchase or transfer of real estate. Check the current guidance for your circumstances.

What about off-the-plan and developer sales?

Selling or transferring real estate as part of a business selling real estate can be a designated service. AUSTRAC gives house-and-land packages, off-the-plan apartments and subdivision lots as examples. The service generally starts when there is a commitment to sell or transfer the property.

Do I need to enrol if I am a sole trader?

Business structure alone does not decide whether you are regulated. Check whether the services your business provides are designated services, then follow AUSTRAC's current enrolment guidance.

When does a real estate agent start providing a designated service?

For a seller's agent, AUSTRAC says this starts for the seller when the brokerage agreement is signed. For the buyer, it typically starts when an offer is accepted and the contract is signed. Buyer-agent timing is different, so check AUSTRAC's real-estate guidance for the full detail.

When do I need to lodge a Suspicious Matter Report (SMR)?

AUSTRAC says you must submit an SMR within 24 hours of forming a terrorism-financing suspicion, or within 3 business days for other suspicions. Submit through AUSTRAC Online and do not tip off the customer.

How long do I have to keep client records?

Retention depends on the record type. AUSTRAC says customer due-diligence records must generally be kept for 7 years from the end of the business relationship or completion of an occasional transaction; other AML/CTF records also have specific retention rules.

What does enrolment with AUSTRAC involve?

AUSTRAC set 29 July 2026 as the transition enrolment date for newly regulated businesses that began providing designated services from 1 July 2026. The enrolment form asks for business, service and applicant details. The general enrolment rule is within 28 days of starting a designated service — check current AUSTRAC guidance for your circumstances.

Sources and further reading

Disclaimer: This guide is general information only and is not legal, financial or compliance advice. AMLHive is not affiliated with AUSTRAC or the Australian Government. Obtain independent professional advice for your circumstances and check the current AUSTRAC guidance, AML/CTF Act and Rules before relying on the information above.