Question 1

Does AUSTRAC Tranche 2 apply to all Australian states?

Accepted Answer

Yes. The AML/CTF Act is federal legislation and applies uniformly across all Australian states and territories. Whether you're in NSW, Victoria, Queensland, WA, SA, Tasmania, or the territories — the obligations are identical.

Question 2

Does AUSTRAC Tranche 2 apply to property management?

Accepted Answer

Property management on its own — collecting rent, managing tenants, handling maintenance — is not a designated service under Tranche 2. However, if your agency also brokers property sales or purchases alongside property management, you are captured for the sales activity.

Question 3

Do real estate agents need to verify buyers under AUSTRAC?

Accepted Answer

Yes. Under the AML/CTF framework, both the buyer AND the seller are your customers. You must conduct customer due diligence on both parties to a transaction, including identity verification, risk assessment, and sanctions screening.

Question 4

What happens if a real estate agency is not compliant with AUSTRAC by July 2026?

Accepted Answer

AUSTRAC can impose civil penalties of up to $33 million for body corporates and $6.6 million for individuals. They can also issue remedial directions, enforceable undertakings, and infringement notices. Enforcement actions are published publicly on AUSTRAC's website.

Question 5

Can I use the free AUSTRAC starter kit instead of a compliance service?

Accepted Answer

AUSTRAC provides a Real Estate Program Starter Kit, but it's a generic template that requires significant customisation to reflect your agency's specific services, client base, geographic exposure, and risk profile. Most agencies need professional assistance to properly implement it.

Question 6

How much does AUSTRAC compliance cost for real estate agencies?

Accepted Answer

The Attorney General's Regulatory Impact Statement estimates compliance costs of $23,250/year for Tranche 2 entities. Law firms charge $15,000-$30,000. AustracCheck provides a complete compliance package from $3,500 — delivered in 5 business days.

Question 7

What is AUSTRAC Tranche 2?

Accepted Answer

AUSTRAC Tranche 2 refers to the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024, which extends AML/CTF regulations to 'gatekeeper professions' including real estate agents, buyer's agents, and property developers. These businesses must comply with AML/CTF obligations from 1 July 2026.

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