Do property managers need AML compliance in Australia?
Property managers are asking whether AUSTRAC's Tranche 2 reforms apply to them. The short answer: it depends on what your agency does — and many property management arms are in scope. Here is how to find out.
Your property management team handles hundreds of rental applications, landlord payments, and lease renewals each month. None of that feels like money laundering territory. So when the AML/CTF obligations conversation comes up, most property managers assume it is a sales-desk problem.
That assumption is worth checking.
The fast path: check your scope in the platform
Before working through the detail, here is the quickest way to answer the question for your agency: AML Simple's onboarding wizard asks about the services your agency provides — sales, leasing, property management, commercial, buyers agency — and maps those against the regulated service definitions.
If you are in scope, the wizard takes you straight into building your AML/CTF program. If your property management function turns out to be out of scope, you will know exactly why.
Start the scope check — takes about 3 minutes →
What Tranche 2 actually covers
Under the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024, the regulated "designated services" for real estate include:
- Buying or selling real property — acting as an agent in the sale or purchase of residential or commercial property
- Leasing real property — acting as an agent in the leasing of real property
The second category is the one property managers need to read carefully.
AUSTRAC's guidance confirms that agencies acting as agents in leasing transactions — not just sales — are regulated entities. If your property management arm negotiates leases and acts as agent between landlord and tenant, that is a regulated service under the AML/CTF Act 2006 (as amended).
Source: Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024; AUSTRAC real estate sector guidance
Where property managers often get it wrong
The confusion usually comes from one of three places:
1. "We only manage rentals, we don't sell."
Leasing is a regulated service in its own right. An agency that does only property management — no sales — is still a reporting entity if it acts as agent in negotiating leases.
2. "Our franchise group is handling it."
Franchise group programs cover the franchise as an entity, not your individual agency. Every agency that is a separate reporting entity must enrol with AUSTRAC and build its own AML/CTF program. See our breakdown of what AUSTRAC Tranche 2 obligations mean for real estate agents for how reporting entity obligations work at agency level.
3. "Property management is low-risk, so thresholds probably apply."
There are no volume or value thresholds. An agency that completes a single lease transaction as agent is a reporting entity. The rules apply from the first transaction on or after 1 July 2026.
What obligations apply if property management is in scope?
If your agency's property management function is in scope, the same full suite of obligations applies as for the sales desk:
- Enrol with AUSTRAC — before you provide any designated service
- Build an AML/CTF program — covering risk assessment, CDD procedures, staff training, and record keeping
- Complete CDD on landlords and tenants — before or at the time of establishing a new leasing relationship
- Screen against DFAT sanctions lists — at onboarding and on an ongoing basis
- Report suspicious matters — via AUSTRAC's AUSTRACK Online portal
- Keep records for 7 years — all CDD records, transaction records, and program documents
The AUSTRAC Tranche 2 complete guide covers each of these obligations in full if you want the detail on any specific requirement.
One program — or two?
If your agency does both sales and property management, you do not need a separate program for each. Your AML/CTF program should cover all the designated services your agency provides. The risk assessment section of the program is where you document the money laundering and terrorism financing risks relevant to each service type.
In practice, the risk profile for property management leasing is somewhat different from residential sales — rental fraud, foreign-based landlords, and high-volume cash payments all feature in property management risk scenarios. Your program needs to reflect those, not just copy the sales-focused version.
AML Simple's program wizard handles multi-service agencies. You set up your agency profile with all the services you provide, and the risk assessment module generates questions relevant to each one.
The enrolment deadline
AUSTRAC enrolment is already open. Agencies that will be providing regulated services from 1 July 2026 should enrol now — waiting until June creates unnecessary pressure, and your AML/CTF program must be in place before you provide the regulated service, not after.
If your property management team is leasing properties on 1 July, your program needs to be operational on that date. That means the risk assessment, CDD procedures, and staff training must all be complete before July.
Not sure if you are in scope?
The scope question is worth resolving properly, not guessing at. If you are in scope and not compliant, the penalties are significant — up to A$33 million per contravention for a body corporate under the AML/CTF Act 2006.
Use AML Simple to check your scope and, if you are in, build your program from the same session. The platform is designed for agencies without dedicated compliance staff — the questions are plain language, the structure follows AUSTRAC's own Program Starter Kit, and every step is logged.
Check your scope and start your program →
For the full picture of what CDD requires when your agency does conduct sales, read Customer due diligence for real estate agencies: a complete guide.
This content is general information only and does not constitute legal or AML/CTF advice. AML Simple is a compliance workflow tool. For advice specific to your situation, consult a qualified AML/CTF compliance professional.