ResidentialPartner ContentWed 03 Jun 26
How AML/CTF Tranche 2 Will Reshape Property Transactions
Australia’s property industry is approaching a major compliance shift and for many businesses, the window to prepare is closing faster than expected.
From July 1, 2026, AUSTRAC requires entities providing captured real estate designated services to comply with Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) obligations, including enrolment and customer due diligence requirements before providing those services.
The reforms are part of a broader effort to close avenues that can be exploited for money laundering and terrorism financing.
The challenge for the property sector is not simply understanding that change is coming. It is working out how to implement it across transactions that are already complex, multi-party and time-sensitive.
Tranche 2 extends AML/CTF regulations to professional services sectors previously outside the regime, including real estate agents, lawyers, conveyancers and property developers selling directly to purchasers.
These businesses must verify the identities of buyers and sellers, identify the individuals behind any purchasing entity, monitor for suspicious activity and report it to AUSTRAC where required.
For developers, that puts sales teams, deposit processes and purchaser onboarding directly within scope.
That reality was front and centre at an AML/CTF Tranche 2 Property Briefing hosted by Ammoze in Sydney in May.
The event brought together leading financiers, solicitors, agents and developers to examine what the incoming reforms mean in practice.
The panel, hosted by Ammoze national director Tom Ogilvie, featured Ashurst partner Hong-Viet Nguyen and Mark Carlisle Group co-founder Carlos Boustany.
The complexity of multi-party transactions
Boustany said that the legal exposure for businesses that misread their captured services is significant and that many in the industry are still conflating their general compliance obligations with the specific requirements Tranche 2 introduces.
“One of the clearest themes we are seeing is a noticeable divide in the industry’s understanding of designated services,” Boustany said.
“Many stakeholders are still working through whether their role is captured, when obligations apply, and how those obligations interact across a transaction.”
A key theme from the briefing was the issue of multiple designated services. Many stakeholders in a property transaction may provide more than one designated service captured under the reforms. Businesses cannot simply focus on the easiest or most obvious part of their role.
Where multiple designated services are provided, each needs to be understood, assessed and supported by appropriate processes.
A single property sale can involve developers, agents, solicitors, conveyancers, financiers, deposit holders and other service providers.
Each party may hold different information. Each may touch the customer at a different point in the journey. The risk is that compliance becomes fragmented.
The questions from the room reflected that concern. Who is responsible for collecting which information? When does customer due diligence need to happen? How do parties avoid duplication without creating gaps? What happens when one stakeholder assumes another has completed a step?
These are not theoretical questions. They go to the heart of how property transactions will be managed from July 2026 onwards.
Where accountability sits
One of the strongest takeaways from the session was that accountability cannot be outsourced by assumption.
Launched in May 2025, Ammoze is a payments and deposit infrastructure platform built specifically for off-the-plan property transactions.
Ammoze sits on the exact pressure points Tranche 2 brings into focus: purchaser onboarding, verification, secure payment flows, deposit handling and transaction visibility.
It creates a clearer pathway for funds and information across a transaction, so stakeholders know who is responsible for what—and when.
“Ammoze is focused on helping bridge that gap by creating a clearer connection between service providers and consumers when AML/CTF checks are required, as well as providing designated services directly in certain instances through its role as deposit holder,” Ogilvie said.
The reforms will require property businesses to build systems specific to their role, their customers, their risk exposure and the services they provide.
For some, this may mean updating onboarding procedures. For others, it may mean creating new controls around purchaser verification, deposit handling, record keeping and transaction monitoring.
Beyond compliance
The property sector has long relied on established transaction workflows. Tranche 2 requires the industry to look more closely at the points where money, identity, contracts and professional services intersect, and to identify where each business is directly responsible, rather than assuming compliance sits elsewhere in the transaction chain.
The opportunity is not just to comply. It is to modernise how property transactions are managed.
Tranche 2 may be the catalyst for a more coordinated approach, with better systems, clearer responsibilities and stronger protections for every party in a sale.
The businesses that prepare early will move through it with the least friction.
To see how Ammoze supports purchaser verification, deposit handling and transaction visibility under the new regime, get in touch with their team.
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