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Tranche 2 — obligations from 2026

Real estate agents

From 2026, real estate agents buying/selling on behalf of clients become reporting entities under the AML/CTF reforms.

AML/CTF Amendment Act 2024 — Tranche 2 Reform

AML/CTF Obligations

Enrol with AUSTRAC before providing any designated real estate services

Implement a written AML/CTF program tailored to your business

Conduct CDD on both buyers and sellers at the commencement of the relationship

Verify the source of funds to be used in the property transaction

Identify beneficial owners of any corporate or trust purchaser

Lodge SMR reports within 3 business days of forming a suspicion

Maintain all CDD records for a minimum of 7 years

Required reports:SMR

Real estate professionals must lodge SMR reports with AUSTRAC within 3 business days of forming a suspicion about a transaction, client, or property transaction. You must not disclose to the client that an SMR has been filed.

Typical Customer Risk Profiles

1

All-cash buyers — purchasers paying entirely in cash without a mortgage raise immediate ML risk flags. The source of funds must be documented and verifiable before you can proceed.

2

Foreign buyers with no Australian financial footprint — offshore purchasers, particularly from high-risk jurisdictions, who have no verifiable financial history in Australia require enhanced scrutiny.

3

Corporate and trust purchasers — when a company or trust is buying, the true beneficial owner must be identified. Complex offshore structures used to buy Australian property are a well-known laundering method.

4

Purchasers seeking rapid settlement — unusual urgency around settlement timing, combined with unclear fund sources, is a recognised red flag in property transactions.

Recommended Compliance Pack

Real Estate Pack

Pre-configured for Real estate agents — KYC rules, risk thresholds, AUSTRAC report templates, CDD workflows, and monitoring rules aligned to your obligations. Ready from day one.

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What's included

System default — customisable

Guided CDD workflows for both buyer and seller — identity verification and document collection in minutes

Beneficial ownership mapping tool for corporate and trust purchasers with UBO identification

Source of funds verification with document upload and review capability

PEP and sanctions screening integrated into the buyer and seller onboarding workflow

SMR preparation and case management for investigating suspicious transactions

Example workflow

Default — you can modify steps
1

Listing accepted — buyer found

New transaction triggers a CDD check. Buyer and seller intake forms sent automatically.

2

Identity verified

Both parties complete digital ID verification. Documents uploaded and stored securely.

3

Buyer risk assessed

Buyer profiled — cash purchase? Foreign buyer? Corporate structure? Risk score assigned and EDD triggered if required.

4

Source of funds documented

Buyer provides bank statements or financial records confirming the legitimate origin of purchase funds.

5

Beneficial owners identified

If a company or trust is buying, VeriGo maps the ownership structure to identify the real people in control.

6

Transaction proceeds or is escalated

Clean transactions proceed. Red flags escalate to SMR preparation. Full audit trail retained for 7 years.

Pricing Recommendation

Recommended

Essential

Most real estate professionals need solid CDD, source of funds documentation, and SMR capability. The Essential plan covers these core obligations from day one. Scale to Professional if your volume or transaction complexity grows.

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Ready to get compliant as a Real Estate?

Your Real Estate Pack is configured on day one. 7-day free trial — no credit card, no consultants, no configuration sprints.