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From 1 July 2026, real estate professionals in Australia who facilitate property transactions or manage client funds become reporting entities under the AML/CTF Act. This guide explains who is captured, which activities trigger your obligations, and how ClearAML helps you verify vendors and purchasers, monitor transactions, and stay compliant — all from your phone.

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Who is captured by Tranche 2?

The Tranche 2 reforms apply to real estate professionals who are involved in any of the following:

Sales agents

Agents who broker or facilitate the sale or purchase of residential or commercial property on behalf of a vendor or purchaser.

Buyer's agents

Agents who search for, evaluate, or negotiate the purchase of property on behalf of a buyer.

Property developers

Developers who sell newly built or off-the-plan properties from their own developments directly to buyers.

Property managers

Property managers who hold, receive, or disburse client funds — such as rental income or bond money — in the course of managing a property.
Property managers who do not handle client funds and are not involved in facilitating sales may not be captured. If you are unsure whether your specific role triggers Tranche 2 obligations, use ClearAML’s eligibility checker.

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What triggers your compliance obligations?

Your AML/CTF obligations are triggered at the point you begin providing a designated service. In a real estate context, this means:
  • Listing a property for sale on behalf of a vendor
  • Accepting an offer from a purchaser
  • Entering a property management agreement that involves handling client money
  • Selling a development off-the-plan or upon completion
You must verify the identity of both the vendor and purchaser before the transaction proceeds.
Obligations are live from 1 July 2026. Enrol with AUSTRAC before 29 July 2026. Failure to comply can attract penalties of up to 22.2millionpercontravention∗∗forcorporationsand∗∗22.2 million per contravention** for corporations and **2.22 million for individuals.

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Your AML compliance checklist

Before 1 July 2026, make sure your agency has completed each of the following:
  • Enrol with AUSTRAC as a reporting entity
  • Appoint a Compliance Officer (can be the principal or a senior staff member)
  • Implement a written AML/CTF Risk Management Program
  • Verify the identity of all vendors and purchasers
  • Screen clients against PEP and sanctions watchlists
  • Maintain forensic audit logs of all identity checks for 7 years
  • Report suspicious matters to AUSTRAC via an SMR

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Vendor and purchaser verification workflow

1

Create a property file

Add a new property transaction in ClearAML, linking it to the street address. You can manage all vendor and purchaser verifications together under a single property file so nothing gets lost between listing and settlement.
2

Send a verification link to the vendor

With one tap, send the vendor a secure link. They complete biometric identity verification on their own phone in under 60 seconds — no photocopying, no office visit required.
3

Send a verification link to the purchaser

Once an offer is accepted, send the same secure link to the purchaser. Both verifications are stored against the property file with time-stamps and audit records.
4

Review PEP and sanctions screening results

ClearAML automatically screens each verified client against global Politically Exposed Person (PEP) and sanctions watchlists. Any matches are flagged for your review before the transaction continues.
5

Generate the risk assessment

The risk engine scores each client based on their type, geography, and transaction details. Your compliance officer reviews the score and the system produces a Risk Assessment record attached to the property file.
6

Keep your audit trail

Every check, decision, and document is stored in a forensic audit log linked to the property address. Records are retained for 7 years in Australian data centres and available for AUSTRAC review at any time.

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Key features for real estate professionals

ClearAML is designed to be used in the field. You can initiate a check, have a vendor scan their driver’s licence, and complete a biometric liveness check while standing in the property — no paperwork, no delay.
All vendor and purchaser ID checks are linked to the property address in one secure, searchable place. Principals can monitor their whole team’s compliance from the office dashboard in real time.
Stop guessing whether a client is high risk. The risk engine calculates scores based on client type, industry, and geography and flags clients that require enhanced due diligence.
Every action is time-stamped in a tamper-evident forensic ledger. You are always ready for an AUSTRAC review, regardless of which team member handled the check.
Generate the reports required for your annual compliance report, independent reviews, and Suspicious Matter Reports (SMRs) directly within ClearAML.
ClearAML’s built-in training module teaches your sales team how to spot money laundering red flags — at no extra cost, with no need to pay for external AML courses.

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Frequently asked questions

Yes. ClearAML is purpose-built for the Tranche 2 reforms, covering real estate agents, lawyers, and accountants. It handles the full compliance workflow required by the legislation.
Yes. ClearAML generates a disbursement receipt for every check. You can bundle the fee into your Vendor Paid Advertising (VPA) schedule so it does not cost your agency anything.
No. ClearAML is mobile-first. You can initiate a check, scan a driver’s licence, and verify a vendor while standing in their home at the listing presentation.
You can be fully set up in under 10 minutes. Start a free 14-day trial, add your team, and send your first verification link the same day — no credit card required.
Yes. ClearAML uses AES-256 bank-grade encryption and hosts all data on Australian servers to ensure data sovereignty. Client data is never sold or shared.