Your go-to resource for AML/CTF answers
Our AML FAQ page brings together the most common questions to help you navigate your Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) obligations. Whether you’re looking for practical guidance, key dates, or clarity on compliance requirements, you’ll find straightforward answers and helpful resources in one place.
What is Anti-money laundering (AML)?
Anti-money laundering is the term used for the combined laws and regulations in place, to stop money obtained via illegal activity such as crime from being transformed into legitimate sources of income.
The process of money laundering is often described as ‘washing money’ when ‘dirty’ or illegal funds become ‘clean’ and appear legal. A common form of money laundering is through the purchase and sale of property.
Examples of Money-laundering through Real Estate
Using illicit funds to:
- Purchasing a house, apartment or commercial building
- Collecting rental income on a property purchased with illegally obtained funds
- Benefiting financially through appreciation in value of a property purchased with illegal funds
What is counter-terrorism financing (CTF)?
The concept of counter-terrorism financing is providing the money used by terrorist organisations to undertake activity that threaten national and international security.
For more information on counter-terrorism financing, visit the Australian Home Affairs website.
Who is AUSTRAC?
AUSTRAC (Australian Transaction Reports and Analysis Centre) Australia’s financial intelligence unit and anti-money laundering and counter-terrorism financing regulator, responsible for detecting and preventing money laundering, terrorism financing, and other financial crimes.
It works to protect the Australian financial system by ensuring businesses comply with Anti Money Laundering & Counter Terrorism Financing regulations.
Key roles include:
- AML/CTF oversight to ensure reporting entities remain compliant
- Monitoring and reporting financial transactions to identify any suspicious activities
- Risk assessment and guidance
- Supporting agencies like Australian Federal Police (AFP) to assist with criminal investigations, often relating to money laundering or terrorism financing.
Do the AML/CTF requirements apply to brokers?
Yes, the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) requirements apply to brokers.
The extent of the obligations depends on the designated services provided.
Real estate and finance brokers are subject to AML/CTF obligations and considered a reporting entity if they provide certain ‘designated services’ outlined in the AML/CTF Act.
Visit AUSTRAC for more information.
When do we need to enrol with AUSTRAC and is it a once-off or annual process?
A business must enrol with AUSTRAC if they provide designated services under the AML/CTF Act.
Enrolment is a one-off process, and businesses must enrol within 28 days of providing a designated service
Enrolment for tranche 2 entities will open on 31 March 2026, and you must be enrolled by 1 July 2026.
What is the difference between tranche 1 and tranche 2?
Tranche 1 was introduced in 2006, focusing on establishing AML/CTF compliance for financial institutions such as banks, insurance companies and credit unions. It required these entities to implement basic anti-money laundering measures, like customer identification, processes, reporting suspicious transactions and submitting large transaction reports.
Tranche 2 expanded the scope significantly to include additional high-risk sectors such lawyers, accountants, real estate agents, property developers, and precious stone dealers.
Under Tranche 2, businesses in these sectors were required to implement more robust AML/CTF programs, including ongoing risk assessments, customer due diligence (CDD) and reporting obligations.
Additionally, penalties for non-compliance became more severe, with greater regulatory oversight.
The new Tranche 2 AML/CTF requirements will come into effect in July 2026.
What happens if I do not comply with AML/CTF regulations?
Non-compliance with AML regulation can lead to severe consequences, including substantial fines, civil penalties (court-ordered fines) and even criminal penalties for serious violation of the AML/CTF laws.
For more information visit AUSTRAC.
Where can I find more information on AML/CTF?
PEXA is sharing this information to help spread the awareness of these big changes facing the conveyancing industry and it should be treated as informational.
For more information visit AUSTRAC’s website where you can find detailed information and guidance in the Business and AML/CTF Reform sections. These include how-to guides, compliance checklists and more.
For formal process like enrolment reporting and updates use the AUSTRAC Online Portal. Use the ‘check if you need to enrol’ tool to assess your obligations.
