Tranche 2 · Real Estate
Compliance that doesn’t slow the deal
Agents, buyer’s agents and certain developers captured when brokering or selling real estate. Property management and pure leasing generally outside scope. Verification and risk assessment designed for speed so deals keep moving.
Am I captured?
Agents, buyer’s agents and certain developers are captured when they broker or sell real estate.
Designated services include:
- Brokering or selling real estate (including acting for a buyer or seller on a sale)
- Certain development sales where you are arranging the disposal of property
Property management and pure leasing are generally outside scope.
Your obligations
If you provide a designated service, you are a reporting entity. You must enrol with AUSTRAC, run a risk-based AML/CTF program, identify and monitor clients, keep records and report when the law requires it. For agencies the duty attaches to the deal, not the rent roll. You need to know who the parties are before the contract is exchanged, and keep that evidence if AUSTRAC later asks how the sale was checked.
AUSTRAC enrolment
Enrol with AUSTRAC and keep the enrolment current — including nominating a Compliance Officer. Enrolment is how AUSTRAC knows you are a reporting entity and how it contacts you.
Risk assessment
Document how your firm could be used for money laundering or terrorism financing — clients, services, delivery channels and geography — and keep that assessment current as the practice changes.
AML/CTF program
Put in writing how the firm will meet its AML/CTF duties: who does what, how clients are identified, how higher-risk work is handled, how staff are trained and how you will check the program still works.
Customer due diligence
Identify the client (and beneficial owners where relevant), verify that identity, screen for PEPs, sanctions and adverse media, and apply extra checks when risk is higher. Repeat when circumstances change.
Reporting
Submit suspicious matter reports to AUSTRAC when you form a suspicion, and any other reports that apply to your services. Do not tip the client off that a report has been made or is being considered.
Record-keeping
Keep the program, risk assessment, identification records and transaction records for at least seven years so you can show AUSTRAC what you did and why.
How Trancher helps
Build client verification, risk assessment and record-keeping into the deal, so the parties are checked before exchange and the evidence is retained in an audit-ready trail.
Risk assessment and AUSTRAC-aligned program builder
Client verification (KYC/KYB) with PEPs, sanctions and adverse media screening
Ongoing monitoring and risk scoring
Reporting support (SMRs)
Staff training modules
Audit-ready records and dashboard
Three clear paths
Choose the level of support that works for your agency — manage compliance yourself, add expert support when you need it, or have agreed activities managed for you.
1
Self-managed
Run your AML program through Trancher using clear workflows and built-in guidance.
From $9.99 per week.
2
Self-managed + expert support
Use the platform day to day and bring in our compliance specialists when you need help with set-up, risk assessment, program development, onboarding, training or first files.
3
Fully managed by our experts
Ask our experienced compliance specialists to manage agreed AML compliance activities on your organisation’s behalf.
How long does it take?
Most firms move from start to operational compliance within weeks.
Days 1–7
Enrolment and risk assessment underway
Days 8–21
Workflows live and team trained
Thereafter
Fully operational and audit-ready
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View article →Questions from real estate agents
Am I captured?
Agents, buyer’s agents and certain developers are captured when they broker or sell real estate. Designated services include brokering or selling real estate (including acting for a buyer or seller on a sale) and certain development sales where you are arranging the disposal of property. Property management and pure leasing are generally outside scope.
What are the deadlines?
Tranche 2 obligations commenced on 1 July 2026. Agencies already providing designated services on that date needed to enrol with AUSTRAC by 29 July 2026. If you start providing a designated service later, enrol within 28 days of first providing it. Nominate an AML/CTF Compliance Officer and keep your enrolment current.
What goes in the program?
Your AML/CTF program must include a written risk assessment and the policies and controls to manage ML/TF risks. For real estate agencies the duty attaches to the deal, not the rent roll. The program typically covers knowing who the parties are before exchange, client verification, beneficial ownership where relevant, PEPs/sanctions/adverse media screening, source-of-funds considerations, suspicious matter reporting, staff training and an audit-ready evidence trail.
What does CDD look like in practice?
Identify the client (and beneficial owners where relevant), verify identity, and screen for PEPs, sanctions and adverse media before the contract is exchanged. The parties must be checked before the deal progresses, and the evidence retained so you can show AUSTRAC how the sale was checked. Higher-risk deals attract enhanced due diligence.
How is KYC/KYB charged?
Every verification check triggers one transaction. If you are identifying individuals within an entity (for example directors, beneficial owners or authorised persons), each individual check is a separate transaction and is charged accordingly.
Disclaimer
This is a plain-English guide only and is not a determination of your firm’s status. Whether you are a reporting entity depends on the specific designated services you provide, the facts of each engagement, and the applicable items in the AML/CTF Act. If unsure, use the Am I in scope? guide or seek independent legal advice. Trancher does not provide legal advice.
Ready to simplify compliance?
Book a short overview or speak with our in-house specialists about the right path for your firm.