PROPERTY DEVELOPMENT · TRANCHE 2
AML/CTF compliance for Australian property developers
If you sell or transfer real estate — including off the plan, and including through your own sales team — you are providing a designated service, and the obligations sit with you.
- 1 July 2026AML/CTF obligations begin
- 29 July 2026Enrolment deadline with AUSTRAC
- 2029–2030First independent evaluation, staggered by enrolment identifier
Are you captured?
Developers often assume the obligation sits with the agency handling the sales. Where you sell or transfer real estate yourself, it sits with you as well. Long settlement periods and offshore purchaser interest make the sector a specific focus.
Likely captured
- Selling or transferring real estate you have developed
- Off-the-plan sales, including through an in-house sales team
- Taking deposits directly from purchasers
- Selling through a related-entity sales agency
- Joint venture arrangements where you transfer an interest in real estate
Generally outside scope
- Construction and contracting services alone
- Land banking with no sale or transfer
- Development approvals and planning work
Capture depends on the designated services you provide — not on your profession, your licence or your job title.
What you need in place
Enrol and register with AUSTRAC
Every reporting entity has to be on the register. Enrolment is the entry point for everything else, including how your evaluation timing is set.
Appoint an AML/CTF compliance officer
A named person with the authority, seniority and time to run the program — and AUSTRAC has to be notified of the appointment.
Write an ML/TF risk assessment
Covering your customers, the designated services you provide, your delivery channels and the jurisdictions you deal with, with the reasoning visible.
Document your AML/CTF policies
Policies, procedures, systems and controls that follow from the risk assessment, approved by a senior manager rather than filed unread.
Run initial customer due diligence
Identify and verify your customer before you provide the designated service, at a depth that matches the risk you have assessed.
Screen for sanctions, PEPs and adverse media
Screening at onboarding and again over the life of the relationship, with the result recorded either way.
Trace beneficial ownership
Where the customer is a company, trust or other arrangement, identify who ultimately owns or controls it — and show how you got there.
Keep ongoing customer due diligence running
Monitoring is not an onboarding task. Relationships have to be reviewed and re-screened as risk and circumstances change.
Report suspicious matters
Submit suspicious matter reports within the required timeframes, plus threshold transaction reports where they apply to you.
Keep records
Generally seven years, with the retention clock starting at different points depending on the record type.
Train your people
Risk-appropriate AML/CTF training for staff, refreshed over time and delivered to new starters as they join.
Have the program independently evaluated
An independent evaluation of the whole program on the cycle your policies set, with findings tracked to closure.
Deal with long settlement periods
A purchaser verified at exchange may need re-checking before completion. Build that into the program rather than discovering it at settlement.
Understand the source of funds
Where a purchase is unusual in scale or structure, be able to show what you asked and what you concluded.
See the evidence, not just the promise.
How True Comply helps
Verify at exchange, monitor to settlement
Purchasers verified at exchange and kept under monitoring right through to completion, however long that takes.
Cases grouped by project and lot
A whole release is visible in one view, rather than scattered across spreadsheets.
Purchaser structures traced
Beneficial ownership tracing for the corporate and trust purchasers common in this market.
Screening that flags change early
A shift in a purchaser's risk surfaces before completion, not after.
A program pack for a development business
Written for how a developer operates rather than for an agency.
Senior advisory support
For capital and purchaser structures that need real judgement.
Free to start. $1 per person per month for ongoing monitoring.
Start with your first checks at no cost, then keep your whole client book monitored for a dollar a person a month.
Questions, answered.
Related insights
- Real estate
Tranche 2 is here: what it means for Australian real estate agencies
5 min read
- Scope
‘Are we even captured?’ How AML/CTF scope really works
4 min read
- How to
How to run customer due diligence that stands up
6 min read
- How to
Writing your first AML/CTF risk assessment
5 min read
Compliance you can prove.
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