Why Every Queensland Real Estate Agent Needs to Read This Before July 2026
If you own a real estate agency or buyers agency in Queensland, your regulatory world is about to get bigger. From 1 July 2026, the real estate industry officially becomes a regulated sector under Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws — and whether you’re brand new to the industry or have been selling property for 20 years, these obligations apply to you.
This is the biggest change to real estate compliance in Australia in nearly two decades. In our recent virtual classroom session, we spent a solid 20 minutes unpacking exactly what’s coming, what it means for Queensland agents, and what you need to do right now. Watch the video here
What Is Anti-Money Laundering (AML) and Why Does It Matter in Real Estate?
Anti-money laundering (AML) refers to the laws, regulations, and processes designed to stop criminals from disguising illegally obtained money as legitimate income. The property market has long been recognised as one of the most attractive channels for money laundering — large transactions, relatively complex ownership structures, and historically low regulatory scrutiny made it a soft target.
Money laundering typically moves through three stages:
Placement — illegal funds are introduced into the financial system, often through a property purchase.
Layering — the money is moved and re-moved through transactions to obscure its origin.
Integration — the funds re-enter the legitimate economy, now appearing “clean” through the form of a property asset, rental income, or sale proceeds.
Australia’s property sector has been flagged by the global Financial Action Task Force (FATF) as a significant vulnerability. These reforms are, in part, a response to Australia’s upcoming mutual evaluation by FATF in 2026 — and the consequences of non-compliance extend well beyond individual agents.
What Is Changing on 1 July 2026?
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 received Royal Assent on 10 December 2024. It expands the AML/CTF regime — which previously covered banks, credit unions, casinos, and financial institutions — to include what are called “Tranche 2 entities.“
Tranche 2 entities in real estate include:
- Licensed real estate agents
- Property developers
- Buyer’s agents
- Conveyancers
- Accountants
- Trust and company service providers
From 1 July 2026, if you provide a “designated service” with a geographical link to Australia — which includes brokering or acting as an agent in the buying, selling, or transferring of property — you become a reporting entity under AUSTRAC.
This is not optional. These are federal obligations.
What Does “Reporting Entity” Actually Mean for You?
Once you are a reporting entity with AUSTRAC, you have a defined set of legal obligations. Here is a plain-language breakdown of what that means in practice.
1. Enrol with AUSTRAC
Enrolment for real estate professionals opens on 31 March 2026 and must be completed before you provide any designated service from 1 July 2026. This is done through the AUSTRAC online portal.
2. Develop an AML/CTF Program
You must develop and maintain a written AML/CTF program for your business. This must include:
- A money laundering and terrorism financing (ML/TF) risk assessment specific to your business
- Written policies and procedures to manage those risks
- Designation of an AML/CTF Compliance Officer (this can be you, as a sole operator, or a nominated staff member)
AUSTRAC has released a starter program kit specifically for small, low-complexity businesses in newly regulated sectors — including real estate. This is available on the AUSTRAC website and is designed to help sole operators and small agencies get compliant without needing to engage expensive external consultants.
Note for sole operators and small agencies: AUSTRAC has been clear that they do not expect perfection on day one. They do expect honest effort, documented preparation, and genuine engagement with the risk management process.
3. Conduct Customer Due Diligence (CDD or KYC)
Before providing a designated service, you must verify the identity of your clients and beneficial owners. This includes:
- Verifying the identity of the buyer and seller before proceeding with a transaction
- Conducting enhanced due diligence for higher-risk clients, such as politically exposed persons (PEPs) or customers with unusual transaction patterns
- Ongoing monitoring of client relationships throughout the transaction
For real estate, the duty to conduct CDD begins when you start assisting with a property transaction — not only at settlement.
4. Report Suspicious Matters and Transactions
This is arguably the most significant day-to-day obligation for agents on the ground. You must report to AUSTRAC:
- Suspicious Matter Reports (SMRs) — any transaction or interaction that gives you a reasonable grounds to suspect money laundering or other financial crime
- Threshold Transaction Reports (TTRs) — cash transactions of $10,000 or more
- International transfer information when relevant
Importantly, once you lodge a suspicious matter report, you must not disclose to the client that a report has been made — this is called “tipping off” and is itself an offence.
5. Maintain Records
You must keep records of all CDD processes, transaction documents, and AML/CTF program documentation for a minimum of 7 years.
What Transactions Are Covered — and What’s Excluded?
Not every real estate activity triggers AML/CTF obligations. AUSTRAC has clarified the scope:
Covered (designated services):
- Brokering or acting as agent in the sale, purchase, or transfer of real estate
- Acting as a buyer’s agent in a property acquisition
- Assisting in the transfer of a property that involves money or value being exchanged
Not covered (exclusions):
- General property advice or market discussions (where no transaction is being facilitated)
- Short-term leases of 30 years or less
- Simple referrals to third parties
- Transactions involving movable or temporary dwellings (e.g., caravans)
- Private family transfers not conducted as part of a business
If you’re unsure whether a specific service you provide is captured, AUSTRAC has an online tool at austrac.gov.au to help you check.
Key AML Compliance Dates for Real Estate Professionals
| Date | What Happens |
|---|---|
| 31 March 2026 | AUSTRAC enrolment opens for real estate professionals |
| 1 July 2026 | AML/CTF obligations commence for all Tranche 2 entities |
| 29 July 2026 | Deadline to notify AUSTRAC of your AML/CTF Compliance Officer |
| 1 July 2029 | First independent evaluation deadline for newly regulated entities |
Red Flags: What Should You Be Looking For?
Part of your compliance obligation is knowing what suspicious behaviour looks like in a property transaction context. Common red flags that may warrant a suspicious matter report include:
- A buyer who is unusually eager to settle quickly or offers significantly above market value without negotiation
- A client who is reluctant to provide identification or offers inconsistent identity information
- A transaction involving third-party payments or payment from unusual or overseas sources not connected to the buyer
- A buyer who shows little interest in the property itself but significant interest in the structure of the transaction
- Requests to split payments or conduct multiple smaller transactions to avoid thresholds
- A client who is a politically exposed person (PEP) — a current or former senior government official, or a close associate
You don’t need to be certain that something illegal is happening. The threshold is reasonable grounds to suspect — and in some circumstances, the obligation to report arises even if the transaction ultimately does not proceed.
What Does This Mean for Your Training?
Here’s the direct connection to your professional development: the AML/CTF obligations are not just a compliance tick-box exercise. They require genuine, applied understanding of the laws, the risks, and the reporting processes. That means training is not just recommended — it is part of building the competency required to meet your obligations.
At The Learning Team, we are building AML/CTF content into our real estate training programs to ensure that every student — from those entering the industry through the CPP41419 Certificate IV in Real Estate Practice to experienced agents renewing through CPD — understands what these laws mean and how to apply them in their day-to-day work.
Frequently Asked Questions About AML in Queensland Real Estate
What is AML in real estate? AML stands for Anti-Money Laundering. In real estate, it refers to the obligations placed on agents, buyer’s agents, and property developers to identify, assess, and report money laundering risks in property transactions. From 1 July 2026, these are legal requirements under Australian federal law.
Who does AML apply to in Queensland? All real estate professionals who provide a “designated service” — including licensed agents, sales representatives, and buyer’s agents — must comply with AML/CTF obligations from 1 July 2026. This applies regardless of whether you work for a large agency or operate as a sole trader.
When do I need to enrol with AUSTRAC? Enrolment opens 31 March 2026. You must be enrolled before you provide any designated service from 1 July 2026. Enrolment is done through the AUSTRAC online portal at austrac.gov.au.
What happens if I don’t comply with AML laws? Non-compliance can result in AUSTRAC enforcement action, including civil penalties, significant fines, increased audit and supervision activity, and in serious cases, criminal charges. The penalties are substantial.
Do I need a lawyer or expensive consultant to set up an AML program? Not necessarily. AUSTRAC has published a starter program kit specifically designed for small and low-complexity businesses in newly regulated sectors. Many real estate businesses — particularly sole operators and small agencies — will be able to use this kit to build a compliant program without engaging external advisors. The key is to engage with the process genuinely and document your efforts.
Does AML apply to buyer’s agents? Yes. Buyer’s agents are explicitly listed as real estate professionals who will be regulated under Tranche 2 from 1 July 2026.
What is a Suspicious Matter Report? A Suspicious Matter Report (SMR) is a formal report lodged with AUSTRAC when you have reasonable grounds to suspect that a transaction or client interaction involves money laundering, terrorism financing, or other financial crime. Lodging an SMR is a legal obligation and must be kept confidential — you cannot disclose to the client that a report has been made.
The Bottom Line
The 1 July 2026 deadline is not far away. For Queensland real estate professionals, the message is clear: the time to start preparing is now, not in June.
Start by enrolling with AUSTRAC when enrolment opens on 31 March 2026. Use the AUSTRAC starter program kit to build your AML/CTF program. Understand your CDD obligations before you start a transaction. Know your red flags. And make sure your training keeps pace with the regulatory environment you’re operating in.
This is not a change that will pass you by if you ignore it. It is a fundamental shift in how our industry operates — and professionals who understand and embrace it will be better positioned, more trusted, and more protected than those who don’t.
Watch: AML in Real Estate — Virtual Classroom Session
We covered this in depth in a recent live virtual classroom session. If you want to hear it explained in plain language — with real examples and space for questions — watch the recording above.
Want to Make Sure Your Real Estate Training Covers the Incoming AML Requirements?
The Learning Team delivers the CPP41419 Certificate IV in Real Estate Practice and CPD programs for Queensland agents — built around real regulatory obligations. If you want training that prepares you for how the industry actually operates, get in touch with us here
Published by The Learning Team | RTO 46386 | Queensland Real Estate Training Information in this article is current as at the date of publication and is based on publicly available AUSTRAC guidance. This article is educational in nature and does not constitute legal advice. Always refer to austrac.gov.au for the most current regulatory guidance.