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New AML/CTF Laws Are Coming for Property Sales: What Buyers, Vendors, and Investors Need to Know

Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws are about to change significantly — and if you are buying, selling, or transferring commercial property, those changes directly affect how we work with you.

From 1 July 2026, real estate agents will be required to comply with new obligations under what is known as the “Tranche 2” reforms. At Muller Commercial, we’ve been preparing for these changes well ahead of the deadline. This post explains what the reforms are, who they apply to, and — importantly — who they do not apply to.

What Is Tranche 2, and Why Is It Happening?

Australia’s original AML/CTF framework, introduced in 2005, applied primarily to banks and financial institutions. Real estate has always been recognised internationally as a sector vulnerable to money laundering — large transaction values, complex ownership structures, and the movement of significant capital make property sales an attractive vehicle for those seeking to hide the proceeds of crime.

In November 2024, the Australian Parliament passed the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024, bringing real estate agents, lawyers, accountants, and other “gatekeeper” professions into the regulatory framework for the first time. The legislation received Royal Assent on 10 December 2024 and brings Australia into line with international standards set by the Financial Action Task Force (FATF).

Put simply: Tranche 2 closes a long-standing gap in Australia’s defences against serious and organised crime — specifically around property transactions.

What Changes for Real Estate Agents?

The obligations apply specifically to agents who broker the sale, purchase, or transfer of real estate. This is an important distinction: the legislation explicitly excludes leasing of commercial real estate, residential tenancy agreements, and property management from its scope. Standard commercial leases — including the 5+3 or 3+3 year terms typical in our market — are not designated services under the new framework.

For sales and transfer transactions, agents become reporting entities under Australian law from 1 July 2026. Key requirements include:

• Enrolling with AUSTRAC — final deadline 29 July 2026
• Conducting a formal risk assessment of money laundering and terrorism financing exposure
• Developing an AML/CTF program covering client identification, transaction monitoring, and suspicious matter reporting
• Customer Due Diligence (CDD) — verifying client identity before any designated service is provided
• Ongoing monitoring of client relationships
• Enhanced checks for politically exposed persons or unusual transaction structures
• Reporting suspicious matters to AUSTRAC
• Maintaining records — a documented audit trail

What Does This Mean for You?

The answer is different depending on your relationship with us.

Vendors (property sellers): The obligations apply to your transaction. Before we list your property for sale, we’ll need to verify your identity and confirm your ownership of or authority over the property.

Buyers: Before a purchase is completed, we’ll ask for identification documents and may need to understand the source of funds involved.

Businesses and investors (buying or selling): Where a company, trust, or investment structure is involved, we’ll need to identify the beneficial owners — the people who ultimately own or control that entity. This mirrors how similar laws already operate across banking and legal services.

Landlords (leasing only): If your relationship with Muller Commercial is a leasing or property management arrangement — and it is not connected to a sale or transfer — the Tranche 2 obligations do not apply. Leasing of commercial real estate and property management are explicitly excluded from the new designated services. This is good news for the majority of our property management clients. If you are also selling a property through us, that sale transaction would trigger the obligations, but your leasing and management arrangements remain unaffected.

Tenants: You are not affected. Leasing is excluded from the Tranche 2 framework entirely. There is no change to how we engage with you as a tenant.

Key Dates to Know

Our Commitment to You

At Muller Commercial, we have always built our business on transparency, integrity, and doing the right thing by our clients. The Tranche 2 reforms reinforce values we already hold, and we’re committed to meeting these obligations in a way that is thorough without being burdensome.

We’ve been working through our compliance requirements ahead of the 1 July 2026 start date so the changes are fully embedded before they affect any sale transaction you’re involved in. For the large portion of our clients whose relationship with Muller Commercial centres on leasing and property management — you will notice no change at all. That is exactly as the legislation intends.

We see compliance not as a box to tick, but as part of the professional standard our clients deserve.

Questions? We’re Here to Help

Contact us on 02 4575 3655 or visit mullerre.com.au to get in touch.