AML is coming and what it means for you

The key date for most property clients is 1 July 2026, when new AML/CTF obligations are scheduled to start applying to tranche 2 entities that provide the newly created “designated services”. Newly regulated entities will be able to enrol with AUSTRAC from 31 March 2026.¹

What money laundering means in plain English

“Money laundering” has a specific legal meaning, but in everyday terms it is about trying to make “dirty” money look legitimate. AUSTRAC describes it as dealing with money or other property that is linked to crime and attempting to hide or disguise its true origin or ownership.⁵

The broader purpose of Australia’s AML/CTF framework is to help deter, detect and disrupt money laundering and terrorism financing, and to provide financial intelligence to relevant agencies.⁹

Why property transactions are a focus

AUSTRAC’s National Risk Assessment: Money Laundering in Australia assesses the real estate sector as posing a very high and stable money laundering vulnerability.⁶

The same assessment outlines common ways criminals may try to launder money through property, including manipulating property values, rapid resales at higher prices, using illicit funds to pay for improvements, using rental income to legitimise funds, and using legal structures to conceal beneficial ownership. It also highlights that professional service providers (including lawyers and conveyancers) can be involved in enabling purchases where transparency is limited, particularly where they are not subject to AML/CTF controls.⁶

What is changing and when

The reforms are being implemented through the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024. The reforms establish new “designated services” that trigger AML/CTF obligations for certain businesses, including some services provided by real estate professionals and professional service providers such as lawyers and conveyancers.¹

Importantly, this is a designated services model. That means not every business in a tranche 2 sector will be regulated, only businesses that provide the relevant designated services introduced by the reforms.¹

Some changes have already commenced. The Department of Home Affairs notes the Financial Transaction Reports Act 1988 was repealed on 7 January 2025, and the reformed tipping off offence framework commences 31 March 2025.¹

What this means for you as a buyer or seller

From the client side, the most practical change is that your conveyancer (and other parties involved in the transaction, depending on which services they provide) may need to carry out stronger customer due diligence and ongoing checks. Home Affairs describes customer due diligence as requiring reporting entities to identify and verify the customer (and certain associated persons) and to understand and mitigate the money laundering and related risks linked to providing designated services.¹

In practical terms, you should expect some combination of the following, depending on the transaction and its risk profile:

• More detailed identity checks (and potentially checks on people connected to the transaction).¹
• Questions about who is really buying or selling, especially where someone is acting for another person or where ownership structures are complex.⁶
• More scrutiny of funding arrangements in higher-risk scenarios. AUSTRAC’s real estate sector guidance highlights suspicious activity indicators such as reluctance to complete KYC processes, difficulty explaining the source of funds, or unusual payment behaviour.⁷
• Fewer shortcuts and more documentation upfront, particularly where there are time pressures or attempts to avoid normal verification steps.⁷

Why you may not be told everything

The Amendment Act includes a reformed tipping off offence aimed at preventing disclosures that would, or could reasonably, prejudice an investigation. This is one reason professionals may be careful about what they can discuss if concerns arise.¹

A quick sense of scale using 2025 reporting data

AUSTRAC reporting is significant in volume. In AUSTRAC’s Annual Report 2024–25 (year ended 30 June 2025), AUSTRAC reported:

• 19,374 reporting entities
• 452,951 suspicious matter reports (SMRs)
• 2,038,848 threshold transaction reports (TTRs)

These figures illustrate the scale of reporting and oversight across the AML/CTF system.⁸

How to reduce delays in your next property matter

1. Engage your conveyancer early, ideally before you sign, so any required checks can be completed without holding up key milestones.
2. Have your ID ready (and be prepared to provide additional details if you are buying through a company, trust, or acting for someone else).¹
3. Be ready to explain the funding pathway, especially where funds come from multiple sources or third parties, as unusual funding patterns may raise questions.⁷
4. Avoid last-minute changes to parties or ownership close to settlement without a clear, legitimate reason, as changes in who is involved can increase complexity and checking requirements.⁷

Get settlement-ready for AML

If you are planning to buy or sell property, Contact our conveyancing team now. We will explain what AML/CTF checks may apply to your matter, what documents to prepare, and how to keep your settlement timeline on track.

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