Anti-Money Laundering Obligations for Agents in Queensland: Coming Soon!

Agents: if you’re not ready for this yet, you have to start preparing now!

From 1 July 2026, real‑estate agents and other real‑estate professionals in Queensland will face a significant change in their regulatory landscape: they will become “reporting entities” under the Australian Transaction Reports and Analysis Centre (AUSTRAC) regime, pursuant to reforms to the elegantly named Anti‑Money Laundering and Counter‑Terrorism Financing Act 2006 (AML/CTF Act).

These reforms recognise that real‑estate transactions – especially sales and transfers of property – can present a high risk of money‑laundering or terrorism‑financing activity, and aim to extend traditional financial‑sector obligations into the real‑estate sector.

For agents in Queensland this means that those who broker or undertake sales or transfers of real estate will need to prepare and implement a substantial compliance framework.

This article summarises the nature of the changes, the when and how of implementation, the penalty regime you need to know, and practical steps that agents should take now to be ready.

But in short: it’s more questions, more compliance, more paperwork, and more risk if you don’t get it right.

Nature of the changes

The key features of the reforms are as follows:

1. Expanded designated services 

The new regime will capture certain services relating to real estate, notably brokering the sale, purchase or transfer of real estate on behalf of a client, and selling or transferring real estate in the course of a business.

Property‑management and leasing services are generally not captured.

2. Becoming a “reporting entity” 

Agencies that provide captured designated services will become reporting entities. Obligations include enrolment, risk assessment, customer due diligence, transaction monitoring, suspicious‑matter reporting, record‑keeping, training and independent review.

3. Risk‑based approach 

Agencies must assess the money‑laundering and terrorism‑financing risk inherent in their business, clients, jurisdictions and services, and tailor their AML/CTF program accordingly.

4. Customer due diligence 

Before providing designated services, agencies must identify and verify customers, apply ongoing due diligence, and escalate for enhanced due diligence where risks are higher.

5. Reporting, monitoring and record‑keeping 

Agencies must report suspicious matters, keep extensive records, appoint a compliance officer, conduct training, and undergo independent reviews.

Summary of penalties for non‑compliance

In case you’re thinking about ignoring these changes, the penalties under the AML/CTF Act are significant:

• Civil penalties: 

  • Individuals: Up to 20,000 penalty units 

  •  Corporations: Up to 100,000 penalty units 

  (At $330 per penalty unit, this equates to approx. $6.6M for individuals and $33M for corporations.)

• Other enforcement measures include infringement notices, remedial directions, enforceable undertakings, and registration suspension or cancellation.

• Criminal offences may also apply, with potential imprisonment and large fines.

When and how the reforms come into effect

Final AML/CTF Rules for tranche‑2 entities are expected during 2025.

AUSTRAC enrolment will open earlier than the reforms commence (expected from 31 March 2026). 

The reforms themselves commence on 1 July 2026. 

Preparatory work should commence well before the start date. 

What practical steps will agents need to implement?

This isn’t something you want to be doing at the last minute.

Here is a basic framework to ensure you are ready:

1. Confirm whether your services are captured. 

2. Appoint a compliance officer and establish governance arrangements. 

3. Conduct a full ML/TF risk assessment. 

4. Draft and adopt a tailored AML/CTF Program. 

5. Implement customer identification and verification procedures. 

6. Train staff in AML/CTF obligations and suspicious‑activity recognition. 

7. Implement transaction monitoring, reporting and record‑keeping systems. 

8. Plan for independent reviews of your AML/CTF Program.

   
   

Queensland‑specific considerations

Real‑estate agencies should integrate AML/CTF obligations with existing Queensland licensing, trust‑accounting and disclosure regimes.

Ensure procedures align and keep comprehensive documentation for audit and regulatory review.

This might mean ensuring that your practice management software is capable of recording and tracking any compliance activities that you undertake, should any later review of those processes be necessary.

Don’t Wait – Start Documentation, Training and Record Keeping Now

The introduction of AML/CTF obligations for real‑estate agents represents a major shift for the industry. By preparing early, establishing a strong risk‑based program, and training staff thoroughly, agencies can position themselves to meet their new obligations confidently and effectively.

That said, all new systems and training take time to implement, as well as testing to work out any kinks in the system you want to establish.

For this reason, it’s important you start the process sooner rather than later.

If you need help setting up or testing your compliance, just get in touch and we’re happy to help.