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AUSTRAC Tranche 2 · Real estate

Threshold Transaction Reports (TTR) for real estate

From 1 July 2026, real estate agencies that receive cash or cash-equivalent payments of $10,000 AUD or more must lodge a Threshold Transaction Report (TTR) with AUSTRAC. Here is when a TTR fires, when it does not, and what your workflow needs.

The trigger

A Threshold Transaction Report is required when your agency receives cash or cash-equivalent — in a single transaction or related series — of $10,000 AUD or more (or the foreign-currency equivalent). The lodgement window is short and prescriptive: AUSTRAC requires lodgement within 10 business days of the transaction.

What 'cash' and 'cash-equivalent' mean

  • Physical Australian or foreign currency.
  • Bearer-negotiable instruments (traveller's cheques, bearer cheques).
  • Bullion or gemstones presented at a value above the threshold.

Cleared bank-to-bank funds — the typical settlement path through a solicitor or conveyancer's trust account — are not cash-equivalent. Most residential property deposits and settlements will not trigger a TTR for the agency, because the funds move through regulated banking rails.

The cases that do trigger

  • An agency takes a $10,000+ deposit in physical cash at the office or via a sales agent.
  • A buyer presents bullion or bearer-negotiable instruments above threshold as part of a deposit.
  • Structured payments — multiple sub-$10,000 amounts that look related — are aggregated; AUSTRAC treats these as a single transaction for TTR purposes.

Lodgement workflow

Reports are lodged via AUSTRAC Online. The form captures the transaction amount, customer details, the receiving entity (your agency), and the manner of receipt. AustracCheck generates an AUSTRAC-format draft from the customer record; your agency reviews and lodges through AUSTRAC's own system. Lodgement evidence (reference number, timestamp) is stored against the customer record.

Common mistakes to avoid

  • Treating settlement via solicitor's trust account as a TTR trigger — it usually is not, because the cash leg sits with the regulated bank, not the agency.
  • Missing aggregation — three $4,000 cash deposits inside a week from the same buyer is one TTR, not zero.
  • Lodging late — the 10-business-day window starts from the transaction, not from when the agency notices.
  • Failing to capture supporting identity verification — AUSTRAC expects the TTR to point to the same customer record that holds the verification artefacts.

Suspicious vs threshold reports

If a transaction is below $10,000 but the circumstances suggest money laundering, that is a Suspicious Matter Report (SMR), not a TTR. SMRs have stricter tipping-off rules — AustracCheck flags the customer record so internal handovers stay inside the boundary.

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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.