--- title: "Property Development Sector AML/CTF Compliance | HeadStart Docs" description: "AML/CTF compliance for Australian property developers under Tranche 2. In-house sales, off-the-plan transactions, purchaser due diligence. Download free report." lang: en-AU json-ld: | [ { "@context": "https://schema.org", "@type": "Organization", "name": "HeadStart Docs", "legalName": "HeadStart Docs Pty Ltd", "url": "https://www.headstartdocs.com.au", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png?v=4", "width": 512, "height": 512 }, "description": "AML/CTF compliance digital products and programs for Australian businesses under Tranche 2 regulations. Free program documents and AML Portal. 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[Privacy Policy](/privacy) Essential OnlyAccept All [Skip to main content](#main-content) [ ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) ](/) [Home ](/) Features [Programs ](/programs) Resources Sectors [Log in ](/auth) [Portal](/aml-landing) Property Development Sector # Property developers selling off-the-plan or facilitating settlement are reporting entities. Here's what you need to know before 1 July 2026. From 1 July 2026, new AML/CTF compliance obligations (called Tranche 2) will apply to the Property Development Sector. AUSTRAC enrolment opens 31 March 2026. ![Property developers selling off-the-plan or facilitating settlement are reporting entities. Here's what you need to know before 1 July 2026. professionals](/assets/property-developers-DVuaNVw8.webp) ## The path to 1 July 2026 is defined by clear legislative and regulatory milestones AML/CTF Amendment Act Passed Nov 2024 Finalisation of AML/CTF Rules Aug 2025 Core Guidance from AUSTRAC Oct 2025 Sector-Specific Guidance for Real Estate Early 2026 AUSTRAC Enrolment Opens 31 Mar 2026 Mandatory Compliance Commences 1 Jul 2026 The Australian real estate sector has been assessed as having a high money laundering risk. Professionals are viewed as critical gatekeepers. ## These reforms are driven by ### FATF Standards The primary driver is the Financial Action Task Force (FATF), the global standard-setter for combating financial crime. Australia is a founding member and subject to its peer reviews. ### 2015 Evaluation Gap Australia's 2015 FATF evaluation highlighted a key deficiency: the lack of regulation for "gatekeeper" professions like lawyers, accountants and real estate agents. ### Criminal Exploitation Criminals exploit these professional services to conceal illicit funds, hide beneficial ownership through complex structures and add a veneer of legality to the proceeds of crime. ### Tranche 2 Reforms The Tranche 2 reforms close this long-standing vulnerability, strengthening the integrity of Australia's financial system. ## ML/TF/PF Risks in the Property Development Sector The property development sector faces unique money laundering (ML), terrorism financing (TF) and proliferation financing (PF) risks. If an entity offers designated services, they will need to be aware of and assess the risks in relation to their business and services offered. #### Identity Verification Customer due diligence Inadequate verification of customer identity leading to onboarding of high-risk clients. #### Unusual Transactions Transaction monitoring Failure to detect structured payments or unusual transaction patterns. #### Sanctions Exposure Prohibited dealings Risk of inadvertently dealing with sanctioned entities or persons. #### Beneficial Ownership Ownership opacity Complex ownership structures obscuring the true beneficial owners of assets or entities. ### Industry References [NRA: Money Laundering (2024) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/money-laundering-australia-national-risk-assessment-2024)• [NRA: Terrorism Financing (2024) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/terrorism-financing-australia-national-risk-assessment-2024)• [NRA: Proliferation Financing (2022) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/proliferation-financing-australia-national-risk-assessment-2022)• [FATF NRA Guidance (2025) ](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Money-Laundering-National-Risk-Assessment-Guidance.html) ## Who May Be Captured? The key trigger is designated services. Property developers selling directly to customers through in-house sales teams are likely to be captured. If you are unsure whether you are covered, please take advice. Residential developers House and land packages, apartments Off-the-plan sellers Pre-construction property sales Land subdivision operators Vacant land developments In-house sales teams Direct marketing without agents Whether you are captured depends on the designated services you provide. If unsure whether you're covered, please seek legal advice. Even if you are not covered, you may consider implementing guardrails to ensure you don't accidentally cross lines. ## Once you are a reporting entity, you have six fundamental compliance obligations ### 1. Enrol with AUSTRAC Formally register your practice as a reporting entity. ### 2. Develop & Maintain an AML/CTF Program Create a written, risk-based program tailored to your firm's specific ML/TF risks. This is the cornerstone of your compliance. ### 3. Conduct Customer Due Diligence (CDD) Identify and verify your clients and their beneficial owners before providing a designated service, and monitor them on an ongoing basis. ### 4. Report to AUSTRAC Submit Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs) as required. ### 5. Keep Records Maintain all relevant records of CDD, transactions and your AML/CTF program for prescribed periods. ### 6. Appoint an AML/CTF Compliance Officer Designate a senior individual responsible for the oversight of your program. ## Key AML/CTF Areas for Property Developers Under Tranche 2, property developers with in-house sales teams face new obligations when selling property directly. Our documentation helps you navigate these requirements with confidence. ### In-House Sales Compliance Procedures for AML/CTF compliance when selling directly to purchasers through in-house sales teams. ### Off-the-Plan Transactions Specific controls for managing extended settlement periods, deposit verification and ongoing monitoring. ### Purchaser Identity Verification Initial and ongoing customer due diligence (CDD), including electronic verification methods and document requirements. ### Source of Funds Enquiries Procedures for verifying the source and legitimacy of funds for property purchases. ### Beneficial Ownership Records Requirements for identifying and verifying beneficial owners of purchasing entities. ### Suspicious Matter Reporting Workflows for identifying, escalating and reporting suspicious matters to AUSTRAC. ### Compliance Officer Duties Appointment requirements, role description and ongoing responsibilities for AML/CTF compliance. ## Building an AML Program Building an AML/CTF program for a property developer requires multiple steps. - AML/CTF program framework for property developers - Risk assessment worksheet (ML/TF/PF risks) - Purchaser identification and verification procedures - Off-the-plan transaction compliance workflows - Source of funds enquiry procedures - Suspicious matter reporting procedures - Staff Training Register for tracking completion - Compliance officer role description ![Professionals reviewing AML compliance documentation](/assets/legal-consultation-SdDZg_6z.jpg) ## Ready to Get Started? We can help you get a headstart on your AML/CTF program. Program packs from $249, licensed to you permanently. Portal is free with managed CDD, or run your own CDD on BYO-API plans from $20/month. ### A HeadStart on Compliance Sector-specific compliance documents to help you build your AML/CTF program. ### Ready-to-Customise Resources Lawyer-ready to review for your business. ### Training & Record-Keeping Staff Training Register, Compliance Officer appointment documents and portal-based training record-keeping. [Get Started - Property Development Edition](/programs/property-developers-aml-program) From $249 inc GST · or bring your own program HeadStart Docs™ products are developed with reference to publicly available regulatory guidance. This is general information only and does not constitute legal or professional advice. You should seek advice specific to your circumstances before making compliance decisions. ## Free Resources [ ### Tranche 2 Guide Guide to the AML/CTF Amendments and Tranche 2. ](/tranche-2)[ ### Sanctions Screening Free sanctions search tool for DFAT consolidated list screening. ](/sanctions-search) [From $249 ](/programs/property-developers-aml-program) Related Sectors: [Real Estate](/real-estate)[Conveyancing](/conveyancing)[Law Practice](/law-practice) ### Learn More About Property Developer Compliance [ Property Property Developers as Reporting Entities ](/tranche-2-resources/property-developers-reporting-entity)[ Red Flags What is 'Structuring'? ](/tranche-2-resources/structuring-property-professionals)[ Due Diligence Foreign Buyers & High-Risk Jurisdictions ](/tranche-2-resources/foreign-buyers-high-risk-jurisdictions) ### Free Tools for Property Developers [Implementation Timeline Key dates and milestones for Tranche 2 compliance ](/timeline)[Readiness Test Assess your compliance readiness in 2 minutes ](/risk-calculator)[Sanctions Screening Search Australian sanctions lists and country risk ](/sanctions-search) ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) [![HeadStart Counsel](/assets/headstart-counsel-logo-dark-DW8mV5rY.png)](https://www.headstartcounsel.com.au/)[![HeadStart Search](/assets/headstart-search-logo-dark-C68UhGXl.png)](/sanctions-search)![HeadStart Verify](/assets/headstart-verify-dark-Dtad3197.png) ### Sectors [Accounting](/accounting)[Business Brokers](/business-brokers)[Buyers Agent](/programs/buyers-agent-aml-program)[Conveyancing](/conveyancing)[Insolvency](/insolvency-practitioners)[Legal](/law-practice)[Nominee Director](/programs/nominee-director-aml-program)[Precious Metals, Stones & Products](/precious-metals)[Property Development](/property-developers)[Real Estate](/real-estate)[TCSPs](/tcsp)[Virtual Address](/virtual-address) ### Resources [Free Resources](/tranche-2-resources)[Decision Trees](/decision-trees)[Tranche 2 Guide](/tranche-2)[Podcast](/podcast)[Free Sector Reports](/sector-reports)[Implementation Timeline](/timeline)[Sanctions Search](/sanctions-search)[AUSTRAC Starter Kits](/tranche-2-resources/austrac-starter-program-kits)[Budgeting for Compliance](/tranche-2-resources/budgeting-amlctf-compliance) ### Programs [Portal + AML Programs](/programs)[Pricing](/pricing)[White Label](/white-label)[External CRMs](/integrations)[AML Portal](/aml-landing)[Plug & Play Technology](/plug-and-play)[Lawyer in the Loop](/features/lawyer-in-the-loop) ### Legal [Terms & Conditions](/terms)[Privacy](/privacy) ### Connect [Programs](/programs)[Podcast](/podcast)[Feedback](/report-problem)[Our Mission](/our-mission)[Partnerships](/partnerships) ### Events [AML Conference 2026](/conference) Powered by Stripe SSL Secured 2026 Ready © HeadStart Docs Pty Ltd (ABN 12 691 347 823). 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