Real estate compliance has changed. What AUSTRAC’s reforms mean for developers, agents and project marketers.

From 1 July 2026, real estate falls under Australia’s anti-money laundering regime for the first time. The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 extends AML/CTF obligations to real estate agents, conveyancers, property developers and a handful of other professions that have operated outside this framework since it was introduced for banks and casinos in 2006. AUSTRAC has started publishing sector-specific guidance on what this means in practice, and developers, selling agents and project marketing agencies running off-the-plan projects are all squarely in scope.

Source: AUSTRAC real estate guidance

Disclaimer: This article is general information only and doesn’t constitute legal or compliance advice. AML/CTF obligations vary depending on your business and the services you provide – speak to a qualified compliance advisor or legal practitioner to understand how Tranche 2 applies to you.

Why this exists

Property has long been recognised as an easy way to move large sums of money without much scrutiny. Australia was one of the last FATF member countries without a formal AML regime covering real estate, and these reforms close that gap. If your business enrols a buyer, verifies their identity, or handles documentation connected to a sale, you’re likely a reporting entity once the obligations commence.

Who’s in scope

This isn’t just a developer problem. AUSTRAC’s obligations attach to the activity, not the job title – if you broker, sell, or facilitate a real estate transaction on behalf of someone else, you’re providing a designated service regardless of what your business calls itself. Selling agents and buyer’s agents are named explicitly. And critically for the off-the-plan market, AUSTRAC’s own guidance confirms it makes no difference whether a developer sells through in-house sales and marketing staff or through an external project marketing agency – the designated service applies either way. If your agency runs sales on a developer’s behalf, this obligation sits with you too, not just with the developer you’re representing.

So, what does this require?

Under the new rules, in-scope entities need to:

• Enrol with AUSTRAC before providing a designated service, or within 28 days of first doing so
• Run customer due diligence – identifying and verifying who you’re dealing with, not just at contract exchange but as circumstances change
• Screen for politically exposed persons and sanctions matches
• Keep records of customer identification, transaction details and compliance documentation for seven years
• Report suspicious matters where they arise

None of this is optional, and none of it is a one-off task. It’s an ongoing operational obligation that sits on top of everything else a development team is already managing between exchange and settlement.

The so what for developers, agents and project marketers

This is where it gets uncomfortable for anyone still running settlement on spreadsheets and inboxes. AML/CTF compliance isn’t a document you file once. It’s a live record that has to be accurate, complete, and retrievable for seven years, potentially per buyer, across every project you run or represent. For a developer with several concurrent projects, or an agency selling across multiple developer clients, hundreds of purchasers move through different stages of readiness at once. That can quickly become a data problem.

The projects most exposed here are the ones where buyer information lives in five different places: a broker’s inbox, a conveyancer’s file, a CRM export, a spreadsheet someone updates manually, and whatever the sales agent remembers from a phone call. This gets harder still when a project marketing agency and a developer are both holding separate, partial versions of the same buyer’s record. When AUSTRAC or an auditor asks for a clean record of who a buyer is, when they were verified, and what happened at each stage of the transaction, stitching that together after the fact is the kind of manual reconstruction that turns a routine request into a liability.

Don’t overlook the buyer conversation

Compliance isn’t just a back-office exercise – it changes what you have to say to buyers, and how often. Being asked for identity documents, source-of-funds information, or beneficial ownership details is now a normal part of a regulated transaction, but it doesn’t feel normal to a buyer hearing it for the first time. Handled badly, it reads as suspicion. Handled well, it’s just part of the process.

That difference usually comes down to consistency – whether every buyer gets the same clear explanation, at the same point in their journey, regardless of who on the team is handling their file that day. Left to individual judgment, that consistency is hard to guarantee across a sales team, let alone across every project a developer or agency is running at once.

Get it wrong and the compliance cost isn’t abstract. If every agent explains the request differently, or some buyers never get a proper explanation at all, there’s no consistent process to point to if AUSTRAC or an auditor asks how customer communication was handled. An inconsistent process is itself a finding, not just a customer experience problem.

It shows up on the buyer side too. A buyer who’s blindsided by an identity request mid-transaction, with no context and no warning, can read it as suspicion rather than routine process. Multiply that across a project with hundreds of purchasers and even a small percentage of buyers reacting badly is a real hit to settlement timing and reputation.

What developers, agents and project marketers can do now to meet AUSTRAC compliance

Start by mapping where buyer data lives. Before you can centralise anything, you need to know how many systems currently hold a piece of the picture – sales, legal, finance, and communications each tend to keep their own version.

Standardise what “buyer readiness” means across every project. If finance status, identification, and documentation are tracked differently project to project, your compliance record will be too. A consistent structure per milestone makes the eventual audit trail far easier to produce.

Build the habit of a single, structured record per purchaser — one place that captures milestone progress, documentation, and communication history in a format that doesn’t need to be manually reconstructed under time pressure, and that developer and agency can both see. This is the kind of structured, always-current data layer Settld was built to provide across the settlement phase: every purchaser’s status, documents and communication history tracked centrally and consistently, project after project.

Pay attention to how buyers are settling, not just whether they’re ready. Cash buyers sit outside the usual finance-side checks a bank would otherwise run before a loan is approved, which is why they tend to draw closer attention under a risk-based AML approach. Finance readiness tracking that already distinguishes cash from financed purchasers – a workflow Settld runs as standard across every project – gives whoever is managing the buyer relationship a head start on knowing where that extra scrutiny needs to sit, rather than working it out after the fact.

Treat this as a process change, not a compliance sprint. The 1 July deadline matters, but the bigger shift is operational – moving from reactive, fragmented record-keeping to a settlement process that’s auditable by default, whether you’re the developer holding the project or the agency running sales on their behalf.

Standardise how you explain the request, not just how you make it. Leave it to individual judgment and you get individual outcomes: one buyer gets a clear, reassuring explanation, another gets caught off guard and starts asking questions in the group chat with their broker and their parents. That inconsistency is what turns a routine compliance step into a settlement risk. Settld’s automated communication templates remove the variance: a consistent, pre-approved explanation delivered at the right milestone for every purchaser, on every project, so no buyer’s experience comes down to which team member picked up the phone. Because every message sent through the platform is logged against that purchaser’s record, there’s also a timestamped account of when and how the request was communicated if anyone – the buyer, the developer, or AUSTRAC – ever needs to check.

The bottom line

Tranche 2 doesn’t just add a new compliance checkbox. It exposes how fragmented most settlement processes already are, and puts a seven-year retention clock on that fragmentation – for developers and for the agencies selling on their behalf. Whoever goes into this with a structured, centralised view of every purchaser’s journey will find the compliance obligation manageable. Those still coordinating settlement across inboxes and spreadsheets, especially across two organisations rather than one, are going to find it a lot harder than it needs to be.