AML/CTF Reforms: Essential Updates for Property Professionals in Australia

As a trusted property law firm serving Sydney and beyond, Jaide Law is here to guide you through these changes, ensuring your deals stay compliant and efficient.

Who Is Captured by the Reforms?

The rules focus on Tranche 2 entities providing designated services related to real estate, such as buying or selling interests in Australian land (including fee simple titles or leases over 30 years). Everyday transactions like short-term rentals or one-off family sales are exempt, but regular business activities trigger obligations.

Key groups include:

• Property Developers: Those buying or selling land without an independent real estate agent.
• Real Estate Professionals: Agents, buyers agents, and intermediaries earning fees for facilitating land transfers.
• Lawyers and Conveyancers: Designated services like receiving or dealing with property on behalf of clients (e.g., handling funds or preparing transfer documents) bring you into scope as reporting entities.
• Other Tranche 2 Sectors: Accountants and dealers in precious metals/stones are also included, though the focus here is property.

This national framework applies uniformly in NSW, QLD, and VIC, closing gaps where illicit funds have flowed through property deals.

What Are the Core Obligations?

Compliance centres on risk management and transparency. From 1 July 2026, Tranche 2 entities must:

1. Enrol with AUSTRAC: Mandatory registration as a reporting entity (opens 31 March 2026; deadline 28 April 2026).
2. Appoint a Compliance Officer: An internal lead to oversee AML/CTF efforts.
3. Develop an AML/CTF Program: Conduct a business-wide risk assessment, create policies, and provide staff training to identify and mitigate threats.
4. Perform Customer Due Diligence (CDD): Verify client identities, beneficial owners, politically exposed persons (PEPs), and the source/purpose of funds for each transaction.
5. Report and Record-Keep: Submit suspicious matter reports promptly and retain records for seven years (updated from five in some contexts).
6. Reliance Provisions: You may rely on another regulated entity’s CDD (e.g., a lawyers verification) if documented, streamlining multi-party deals.

These steps align with global standards, helping protect your business from fines up to $22.2 million for serious breaches.

Critical Timelines to Note

Preparation is key, with phased rollout:

• Early 2026: Sector-specific guidance released (expected January, per initial drafts).
• 31 March 2026: Enrolment portal opens for Tranche 2.
• 1 July 2026: Full obligations commence for real estate and other Tranche 2 entities.
• 28 April 2026: Final enrolment deadline.

For current reporting entities (e.g., banks), some changes start earlier on 31 March 2026, but property-focused obligations align with the July date.

Practical Implications for NSW, QLD, and VIC

In fast-moving markets like Sydney’s harbourside developments or Brisbane’s growth corridors, these reforms add upfront checks but enhance trust. Developers may see extended due diligence timelines, while agents could face more ID requests. For lawyers and conveyancers, it’s an opportunity to integrate CDD into standard workflows, reducing risks in fund handling.

Non-compliance risks audits, penalties, and deal disruptions, but early action builds resilience.

Partner with Jaide Law for Seamless Compliance

Navigating AML/CTF doesn’t have to complicate your property goals. As the go-to commercial property law firm in NSW, QLD, and VIC, Jaide Law offers fixed-fee audits, program development, and tailored advice to keep you ahead. Our responsive team turns regulatory hurdles into competitive edges, with clear communication every step.

Ready to assess your Tranche 2 exposure? Contact Jaide Law today for a complimentary assessment to see if the new obligations apply to your business.

Disclaimer – We know most of you get this, but just to be clear, the information above is general and doesn’t consider your unique situation. Please don’t rely on it as a substitute for professional advice. We strongly encourage you to seek appropriate guidance for your specific needs.