Background
What is the AML/CTF
Amendment Bill 2024?
Australia's Parliament passed the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Amendment Bill 2024 on 29 November 2024. The legislation is a national Commonwealth law — it applies in every state and territory, not just Queensland. It modernises Australia's financial crime framework and brings it in line with international standards set by the Financial Action Task Force (FATF), the global body responsible for setting anti-money laundering standards.
For most of the past two decades, these laws applied mainly to banks, financial institutions and payment providers. The 2024 reforms extend them to the real estate sector and other professions under what's known as the Tranche 2 expansion — closing a gap that had existed in Australian law for nearly 20 years.
Before this legislation, Australia was one of only five countries out of nearly 200 FATF members that had not regulated real estate professionals under its anti-money laundering framework. Property has long been identified as a high-risk channel for financial crime — high transaction values, complex ownership structures and the ability to move large sums in a single transaction make real estate attractive to those seeking to disguise the origins of illicit funds. This reform is Australia finally closing that gap.
New Zealand — Australia's closest comparable market — has required the same identity verification from real estate professionals since January 2019. Australian buyers transacting across the Tasman have been subject to these checks for years. Now the same standard applies at home.
Scope
Who does Tranche 2 cover?
This isn't a law aimed at any one type of property professional. From 1 July 2026, the entire real estate ecosystem comes under AUSTRAC's regulation for the first time — anyone involved in facilitating a property transaction is captured:
- Real estate agents — both selling agents and buyer's advocates
- Lawyers and conveyancers (for property and entity transactions)
- Accountants and tax agents (in certain transaction roles)
- Property developers selling off-the-plan or new subdivisions
- Precious stone and metal dealers
Approximately 70,000 additional businesses come under the regime — one of the largest expansions of Australia's financial regulatory framework in recent history.
Specifically named in the legislation: a Buyer's Advocate starts providing a designated service — and AML/CTF obligations begin — when a formal agreement to find or identify a property is signed. The obligations apply from the first day of an engagement.
Agent obligations
What does your buyer's advocate
now have to do?
Under the new laws, buyer's advocates must meet a set of compliance obligations before and during any client engagement.
For buyers
What does this mean
for you?
In practical terms, the main thing you'll notice is that your buyer's advocate will ask for identity documents early in the engagement — before property searches begin and before any offers are made on your behalf. This is completely normal. It's the same process you go through when opening a bank account or applying for finance.
What you'll typically be asked to provide:
- A current government-issued photo ID (passport or driver's licence)
- Proof of address (utility bill or bank statement)
- If buying through a company or trust: details of the entity and beneficial owners
- If buying as a foreign person or entity: additional documentation may apply
Important: you cannot waive or opt out of identity verification. It is a legal requirement — not a discretionary service condition. Any buyer's advocate who skips this step after 1 July 2026 is non-compliant.
It's also worth noting that not all property conversations trigger these obligations. General discussions about whether to buy, or hypothetical market questions, are not designated services under the legislation. The obligations begin once a formal engagement agreement is signed.
Market impact
Why this is good for
property buyers.
Money laundering through property distorts prices, creates artificial demand and can price out genuine buyers competing in already tight markets. It benefits no one except those moving illicit funds. Greater regulatory oversight means:
- More transparency about who is buying and with what funds
- A level playing field for genuine buyers in competitive markets
- Increased confidence for both buyers and vendors that transactions are legitimate
- Alignment with international markets where these obligations already exist
These reforms apply to every corner of the Australian property market — from capital cities to regional and lifestyle markets like Noosa. The transparency they introduce is particularly meaningful in markets that attract strong interstate and international interest, where the movement of large sums of money is common and oversight has historically been limited.
Our approach
How Noosa Property Scout
is prepared.
We have reviewed the AUSTRAC guidance carefully and are ensuring our processes meet the new obligations ahead of the 1 July 2026 deadline. This includes completing AUSTRAC enrolment, implementing a documented AML/CTF program tailored to our client base, establishing clear customer due diligence procedures, and appointing a designated compliance officer.
When you engage Noosa Property Scout, you'll be asked to complete a brief identity verification process at the start of the engagement. We've kept this as straightforward as possible. If you have questions about what's required or why, just ask — we're happy to walk you through it.