Legal Insights
Anti-Money Laundering and Counter Terrorism Financing Reforms: Assisting the property industry to prepare for new regulatory requirements
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02 December 2025
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3 min read
Overview of AML/CTF Reforms
Under new legislation which will come into effect on 1 July 2026, the scope of Australia’s anti-money laundering and counter terrorism financing (AML/CTF) laws have been broadened significantly to capture a wider range of professions and services.[1] The new reforms will update the ‘AML/CTF regime’ which is governed by the Australian Transaction Reports and Analysis Centre (AUSTRAC) and are designed to strengthen Australia’s financial crime prevention framework while bringing it into closer alignment with global standards.
The reforms to the AML/CTF regime include the introduction of a number of new categories of ‘designated services’ which are considered high risk in relation to money laundering and terrorism financing. Providers of these services, will now be classified as ‘reporting entities’ to comply with the AML/CTF regime and obligations.
New designated services and application to the property industry
The new designated services include certain activities related to real estate, as follows:
- brokering the sale, purchase or transfer of real estate on behalf of a buyer, seller, transferee or transferor in the course of carrying on a business; and
- selling or transferring real estate in the course of carrying on a business selling real estate, where the sale or transfer is not brokered by an independent real estate agent.
The reporting entities captured by these new classes of designated services will be required to comply with the majority of their AML/CTF obligations from 1 July 2026 and will be able to register with AUSTRAC from 31 March 2026.
These new designated services are likely to extend the application of the AML/CTF regime to
- real estate agents; and
- property developers and builders (to the extent that they perform designated services).
AML/CTF Guidance Materials
To help you understand and navigate these reforms, our Financial Services team has prepared a range of guidance materials, including an article of the updates, a questionnaire to assist with self-assessment and a helpful timeline to ensure you are ready for the new regime. For newly captured reporting entities within the property industry, we also suggest taking a look at AUSTRAC’s real estate specific guidance and program starter kit, which you can find via AUSTRAC'S website: www.austrac.gov.au
Read our article on the application of the updated AML/CTF regime to property developers.
Are you a property developer, real estate agent or builder and unsure if these reforms apply to you.
Key dates to be aware of and proposed timeline for complying with AML/CTF obligations.
How we can help
Maddocks can assist you in preparing for AML/CTF compliance by:
- providing advice and guidance on:
- conducting an AML/CTF risk assessment for your business; and
- the steps and actions required to be ready to comply with AML/CTF obligations by 1 July 2026.
- providing a template AML/CTF program with relevant policies and internal processes to be prepared to reflect your risk assessment
Please get in touch if you have any questions or would like assistance in preparing for the new AML/CTF regime.
Our team
[1] Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 (Amendment Act)
Legal disclaimer
The information provided by Maddocks on this webpage is general information and is not in the nature of legal advice. Maddocks derives its information from sources which it believes to be accurate and up to date as at the date of publication. Maddocks nevertheless reserves the right to update this information at any time. You should seek legal advice before acting or relying on any information or material which has been made available to you on this webpage. Please contact us for legal advice tailored to your circumstances.
Julian Smith
Julian is a leading corporate lawyer, highly regarded for his pragmatic commercial approach, and for his capacity to work through complex and strategic legal issues and transactions.
View profileNick Sparks
Nick has built a reputation as an outstanding property development lawyer, advising on all types of property developments in the residential, industrial and commercial sectors.
View profileJessica Reid
Jessica is a highly experienced commercial partner, recognised for her unique expertise in real estate and property development.
View profileBettina Sheeran
Bettina has more than 20 years of experience in providing advisory and transactional services relating to real estate transactions nationwide.
View profileMick Garner
Mick advises some of Australia's most prominent fund managers, private equity and venture capital operators in licencing, investments, restructuring and acquisitions, particularly in relation to managed funds and superannuation.
View profileStephen Dyason
Stephen is a corporate and commercial lawyer, who assists clients in a wide range of legal matters.
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