If you run a real estate business in Queensland - or anywhere in Australia - the most consequential regulatory change of the next 12 months is not the Property Law Act 2023. It’s Tranche 2.
From 1 July 2026, real estate agents, buyer’s agents, and property developers will be reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. AUSTRAC will be your regulator. The penalties for non-compliance are not theoretical: civil penalties run into the tens of millions of dollars per contravention, and AUSTRAC publishes its enforcement actions.
Most agencies have not started preparing. They should have, three months ago. This guide explains what’s coming, what you need to do, and how to avoid being caught flat-footed when the obligations switch on.
What Tranche 2 actually means
Australia has had AML/CTF laws since 2006, but they only applied to “Tranche 1” entities - banks, casinos, remittance services, and the like. The original legislation always contemplated extending the regime to “gatekeeper” professions: lawyers, accountants, and real estate. That extension is Tranche 2, and it has finally been legislated.
Real estate is in scope because property transactions are one of the most heavily exploited channels for laundering money. The Financial Action Task Force has been pressuring Australia for over a decade to bring the sector into compliance. From 1 July 2026, that happens.
Who is in scope
Three categories of property professional fall within the new regime: real estate agents (residential and commercial), buyer’s agents acting on behalf of purchasers, and property developers selling stock. Conveyancers and solicitors are also captured under separate but parallel obligations.
If your business provides a “designated service” - broadly, any service in connection with the sale, purchase, or transfer of real property - you must comply.
The eight obligations
There are eight core obligations every agency needs to meet:
Enrol with AUSTRAC.
Complete a documented money laundering and terrorism financing risk assessment.
Implement a written AML/CTF program approved by your principal or board.
Conduct customer due diligence on every client (KYC).
Screen against sanctions lists.
Report suspicious matters to AUSTRAC.
Keep records for at least seven years.
Train staff on their obligations.
Each of these is operational, not theoretical. Customer due diligence in particular will change how listings are taken - you will need to verify the seller’s identity, the source of their funds (if relevant), and beneficial ownership where structures are involved.
The timeline you can’t afford to miss
AUSTRAC enrolment opens 31 March 2026 and closes 29 July 2026. Obligations commence 1 July 2026. That gives reporting entities a three-month preparation window, on paper. In practice, the work needs to happen now: your AML/CTF program, risk assessment, and CDD procedures all need to be operational on day one, not drafted on day one.
The penalties
This is not a soft regulator. Maximum civil penalties for body corporates exceed $33 million per contravention. Maximum civil penalties for individuals exceed $6.6 million. AUSTRAC also has criminal enforcement powers, with imprisonment of up to 10 years for serious contraventions.
Beyond the penalty itself, AUSTRAC publishes enforcement actions. A finding against your agency would carry reputational damage, potential professional consequences with the REIQ and Office of Fair Trading, and almost certainly some loss of vendor confidence.
How agencies should prepare
The practical steps are: appoint a compliance officer (often the principal); engage an AML/CTF specialist or platform provider; draft your AML/CTF program; implement a CDD workflow that integrates with your listing process; sort out your sanctions screening; and train every staff member who has client contact.
The agencies that move first will have a calmer second half of 2026. The agencies that wait until June will be doing rushed paperwork while their competitors are already trading compliantly.
Where SearchX and AMLHUB fit
SearchX is the platform Queensland agencies use for compliant disclosure under the Property Law Act 2023. AMLHUB, our partner, is Australia’s first end-to-end AML platform built for AML/CTF obligations. The two work together and work fast - by the time a Form 2 is being prepared, the seller’s identity and beneficial ownership have already been verified through AMLHUB.
FAQs
Do I need to enrol with AUSTRAC even if I’m a sole-trader agent?
Yes, if you provide designated services. The regime applies regardless of size.
What about agents who only do property management?
Property management on its own is generally outside the designated services definition. If you also do sales, the sales side is captured.
Will my CRM handle AML/CTF compliance?
Most CRMs do not. You will need a dedicated AML platform or module to satisfy CDD, screening, and record-keeping obligations.
What if I miss the 1 July 2026 deadline?
Operating a designated service from that date without enrolment, a program, and CDD is a contravention of the Act. AUSTRAC has both civil and criminal enforcement powers.
How much will compliance cost?
Industry estimates range from $10,000 to $50,000 in year one for a small agency, depending on the platforms chosen. Penalty exposure is orders of magnitude higher.