The three dates that matter
- 10 December 2024 — Royal assent to the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024.
- 31 March 2026 — AUSTRAC enrolment opens for Tranche 2 reporting entities. Agencies can pre-enrol so they are not lodging on the deadline.
- 1 July 2026 — Obligations begin. Customer due diligence, sanctions screening, and reporting must be operational for every captured transaction.
Who Tranche 2 captures in real estate
Three groups are explicitly named in the amended Act: real estate agents, buyer's agents, and property developers. The trigger is the designated service — brokering, selling, or transferring an interest in real property with a geographical link to Australia.
Conveyancers and solicitors fall under their own provisions when they participate in real-property transactions; sole-trader buyer's agents are captured the same as larger agencies.
What being ready on 1 July 2026 looks like
- Enrolment with AUSTRAC lodged.
- Written AML/CTF program (Part A risk-based + Part B customer due diligence) adopted by the agency principal.
- Customer due diligence workflow live — every party identified and verified, every name screened against DFAT and UN sanctions, every decision documented.
- Reportable transaction and suspicious matter reporting paths set up so drafts can be lodged inside AUSTRAC's lodgement windows.
- Staff trained, with role-specific content for sales agents, property managers, principals, and admin.
- Seven-year record retention with an audit log that survives staff turnover.
AustracCheck's role
AustracCheck is a workspace tool — templates, screening, checklists, training, audit log. Every regulatory decision stays with your agency; the platform makes the next required action obvious and keeps the records.
What you should do at each milestone
Before 31 March 2026
Pick the workspace you will run AML/CTF on. Draft your written program. Map your customer mix and risk-rate channels. Brief your principal on the obligations.
31 March – 30 June 2026
Pre-enrol with AUSTRAC. Train staff on the workflow they will run on day one. Dry-run a customer file end to end so onboarding does not stall on 1 July.
From 1 July 2026
Every captured deal flows through the workflow. AustracCheck's audit log timestamps each action, so when AUSTRAC asks for evidence later, the file answers the question.