47 days until the AUSTRAC Tranche 2 deadline (1 July 2026). See pricing →

AUSTRAC Tranche 2 · Real estate

AUSTRAC AML/CTF compliance checklist for real estate

A practical 10-step checklist for Australian real estate agencies preparing for the AUSTRAC Tranche 2 deadline on 1 July 2026. What your agency needs in place, in the order most agencies tackle it.

AustracCheck is a workspace tool; your agency owns every compliance decision. This checklist is the sequence most agencies follow. Use it as a planning artefact — each item lists what AustracCheck covers and what stays with you.

1. Confirm you are captured

If you provide a designated service (brokering, selling, or transferring an interest in real property) with a geographical link to Australia, you are captured. Buyer's agents and property developers are captured under the same Tranche 2 amendments.

2. Enrol with AUSTRAC

Enrolment opens 31 March 2026 via AUSTRAC Online. Your agency lodges this directly. AustracCheck does not lodge on your behalf, but the platform tracks status and the enrolment-number record.

3. Adopt a written AML/CTF program

Part A is your risk-based framework. Part B sets out how you identify and verify customers. The program must be approved by the principal and reviewed periodically. AustracCheck generates a tailored draft from your onboarding questionnaire; the principal owns adoption and review.

4. Risk-rate your customer types and channels

Classify customers (individual, company, trust, foreign buyer, PEP) and channels (in-person, online, agent-introduced). Higher-risk combinations get enhanced due diligence. AustracCheck ships defaults; you tune them for your agency mix.

5. Build the customer due diligence workflow

Every captured deal: identify each party, verify identity to the program's standard, capture beneficial ownership for companies and trusts, and document the decision. AustracCheck runs this per customer.

6. Screen against sanctions and PEP lists

DFAT consolidated sanctions list and UN sanctions list are mandatory. PEP screening is a risk-based component. AustracCheck runs daily list refreshes; the platform flags hits, your agency decides next steps.

7. Set up reporting workflows

Threshold Transaction Reports (TTR) for cash or cash-equivalent transactions $10,000 AUD and over; Suspicious Matter Reports (SMR) when you form a suspicion. AustracCheck generates AUSTRAC-format drafts; your agency lodges via AUSTRAC Online.

8. Train your staff

Annual training, role-specific. Sales agents, property managers, principals, admin staff. AustracCheck's Training Center ships modules and per-staff completion certificates the audit log retains.

9. Set seven-year record retention

Customer files, transaction records, sanctions screening results, training certificates, and program-amendment history all need seven-year retention. AustracCheck's audit log keeps every action timestamped and exportable.

10. Schedule the independent review

The Act requires periodic independent review of the AML/CTF program. AustracCheck does not perform reviews; you engage an external reviewer (lawyer, compliance specialist) and store their report against the program record.

Monthly pricing

Cancel anytime. No setup fee.

Basic
$299/mo

CDD tools, record keeping, sanctions screening.

Most Popular
Professional
$499/mo

Everything in Basic + SMR generator, regulatory alerts, annual report prep.

Enterprise
$999/mo

Everything in Professional + priority support, quarterly reviews.

Frequently asked questions

Are real estate agencies captured under AUSTRAC Tranche 2?+

Most are. If your agency provides designated services — brokering property sales or purchases, selling or transferring real estate — and has a geographical link to Australia, you are likely a Tranche 2 reporting entity from 1 July 2026.

What does my agency have to do by 1 July 2026?+

At minimum: enrol with AUSTRAC, document an AML/CTF program (Part A risk-based + Part B customer due diligence), train staff, keep records for seven years, and lodge any reportable transactions. The exact obligations depend on your services and risk profile.

Does AustracCheck file anything with AUSTRAC?+

No. AustracCheck is a workspace tool. It generates templates, checklists, trackers, and an audit log. Every report you need to lodge with AUSTRAC, your agency lodges through AUSTRAC's own channels.

How quickly can my agency be set up?+

Most agencies are using the workspace the same day they sign up. The platform tailors templates and a compliance checklist from a short onboarding questionnaire (10–15 minutes). Review, customise, and adopt at your own pace.

What are the penalties for non-compliance?+

Up to $33 million for companies and $5.5 million for individuals per breach, plus potential criminal prosecution for serious offences such as tipping off. AUSTRAC publishes enforcement outcomes regularly.

Get your agency compliant before 1 July 2026

AustracCheck is a workspace tool — templates, checklists, sanctions screening, and an audit log — purpose-built for Australian real estate. Every regulatory decision stays with your agency; we make the next right action obvious.