Real estate and property development enter the AML frontline, but is investigation readiness being overlooked?

On 29 November 2024, the Australian Parliament passed a pivotal piece of legislation: the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024. This long-awaited reform significantly reshapes the compliance landscape for Australia’s real estate sector including real estate agents, buyers’ agents and property developers. With these sweeping changes the industry is now on the clock. 

By 1 July 2026, real estate businesses must fully comply with the new regime. Yet, most professionals remain unaware. 

The real estate sector steps into the spotlight 

The 2024 Amendment Act finally includes Designated Non-Financial Businesses and Professions (DNFBPs) in the AML/CTF framework. This group includes real estate agents, buyers' agents, and property developers. Like banks and casinos, property professionals will now be required to: 

• Conduct customer due diligence and verify client identities 

• Monitor and report suspicious activity to Australian Transaction Reports and Analysis Centre (AUSTRAC) 

• Keep records of transactions and identity documents 

• Implement risk-based AML/CTF compliance programs 

A reporting entity must also appoint an Anti-Money Laundering Compliance Officer (AMLCO). This officer must hold a management-level position and is responsible for ensuring the business complies with its AML/CTF obligations. 

In short, the real estate sector is becoming a frontline player in detecting and disrupting financial crime. 

A strict timeline is approaching 

• Enrol with AUSTRAC by 31 March 2026 

• Achieve full compliance by 1 July 2026  

Missing these deadlines could result in substantial financial penalties and significant reputational damage. 

Check if you will be regulated. 

Incident and investigation readiness 

While most commentary focuses on client verification and reporting obligations, another critical point is the ability to effectively investigate before submitting a report. Real estate groups must be able to: 

• Collect facts quickly 

• Assess and connect relevant information 

• Confidently determine whether a transaction should be reported  

Lessons from New Zealand 

New Zealand faced a similar situation in 2019 when it expanded AML obligations to real estate agents. The result was a last-minute scramble across the industry. Many businesses were unsure how to operationalise the new requirements, how to properly investigate transactions, and how to report them in line with regulatory expectations. 

Australia should not repeat that experience. Early preparation, especially in building investigation capability, is the best way to avoid a regulatory crisis. 

Smart investigation tools 

As real estate groups rush to implement due diligence procedures and risk-based programs, many are overlooking a key enabler of AML compliance: a system to support and manage investigations efficiently. 

An Investigation Management Platform can be transformative for an Anti-Money Laundering Compliance Officer (AMLCO) and their team. Platforms like Comtrac can help by provide guided workflows that ensure each investigation follows a consistent and compliant process. Every step, from initial suspicion through to final reporting to regulatory authorities such as AUSTRAC, becomes seamless, reliable and transparent.   

The time to act is now 

The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 marks a turning point in Australia for real estate professionals – real estate agents, buyers’ agents and property developers. Widespread industry awareness and proactive preparation are essential which includes having access to the tools that will help those responsible.