Nearly two decades after Australia first began discussing bringing real estate under anti-money laundering laws, Tranche 2 is finally underway.
From 1 July 2026, Australian real estate businesses that provide an AML/CTF “designated service” must comply with AML/CTF obligations and have an AML/CTF program documented and approved before providing those services.
The clock is ticking, and the agents who leave this until May could find themselves in an expensive, stressful scramble.
Richard Manthel, Founder of AMLHUB, has significant experience in the area.
Back in 2012, while running Robert Walters New Zealand, he spotted an opportunity in the compliance gap and built AMLHUB – a platform that’s since processed half a million property transactions and trained over 10,000 New Zealand agents.
Now Australia can learn from its experience.
What Money Laundering Actually Looks Like
Forget the Netflix dramatisations. Real estate money laundering isn’t about laundromats – it’s about moving dirty money through legitimate property transactions to obscure its criminal origins.
“Real estate is fantastic for that, you can move chunks of cash – millions of dollars – in and out of the real estate market,” Richard explains.
One common risk pattern looks like this: an overseas buyer deposits funds into a real estate (or related) trust account for a purchase, then withdraws and requests a refund or transfer to another party (sometimes split across multiple third parties).
Even if the deal never settles, the “win” can be getting money to flow through a trusted account and back out again.
Global estimates suggest roughly US$800 billion to US$2 trillion is laundered each year, with some estimates as high as US$4 trillion.
Property can be attractive for money laundering because it’s a big-ticket asset – it can absorb large sums and help turn dirty money into something that looks legitimate.
The Leadership Problem Nobody Anticipated
When New Zealand brought real estate under AML laws in 2019, most agencies left preparation until the final months.
But the bigger issue, Richard observed, wasn’t timing – it was leadership.
“A lot of the senior management didn’t really engage fully in AML,” he recalls.
“They created a weak AML culture in the business. Agents were allowed to get away with it.”
The message for Australian principals is clear: this isn’t something to delegate and forget. Senior leaders need to understand their obligations, support their compliance officers, and set the tone for the entire organisation. Richard’s team now regularly delivers board-level training for exactly this reason.
Some experienced agents pushed back hard initially. The “I’ve known my clients for 10 years, why should I do this?” objection was common. Those agents took considerable time to bring around – and in the meantime, they put their entire business at risk.
Why DIY Compliance Is a Dangerous Gamble
AUSTRAC has promised guidance packs for real estate agents, and some principals will inevitably think they can build their own programme from those materials. Richard has seen where that leads.
“If you DIY it and you get it wrong, you set up a systemic failure,” he warns.
“That failure stays in the business for years. When you get audited, they’ll say you’ve done it wrong for the last two years – go back and fix it.”
That remedial action is expensive, time-consuming, and entirely avoidable. The recent enforcement actions against casinos and banks demonstrate that AUSTRAC isn’t shy about using its powers.
Fines, prosecutions, and public naming have all been deployed against entities that got their AML programmes wrong.
The 90/10 Reality
For agents worried about alienating clients with intrusive checks, Richard offers reassurance: the vast majority of transactions are straightforward.
“Ninety per cent of the time, it’s fairly straightforward,” he says.
Standard identification and verification of name and date of birth – whether face-to-face or through biometric tools – handles most situations.
Complex cases involving foreign trusts or offshore structures require deeper investigation, but they are the exception, not the rule.
Ask any New Zealand agent today how AML has affected their business, and you’ll hear the same thing: it’s become business as usual. The process becomes embedded in existing workflows and no longer feels like an imposition.
Start Planning Now
Richard’s advice for Australian agents is simple: don’t wait.
Have your compliance officer identified, your documentation drafted, and your systems chosen by early 2026 at the latest. Understand your obligations at a senior level. And recognise that while half the agents in any room can think of something suspicious they’ve witnessed in the past five years, the difference now is they’ll have the framework to report it.
The agencies that prepare early will find this manageable. Those who leave it until June will wish they hadn’t.
Don’t wait until the deadline is at your door. Reach out to the team at AMLHUB today for expert advice on getting your agency AML ready well before July 2026
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