Property managers vs sales agents: who needs AML compliance?

Quick answer

Sales agents who help buyers or sellers in property transactions are in scope for AUSTRAC Tranche 2 from 1 July 2026. Property managers who only lease and manage rentals are not - with some important exceptions. If your agency does both, you need to understand the split. AML Simple's onboarding wizard maps your services to the regulated definitions in around 3 minutes.

The fastest way to work this out for your agency: sign up at AML Simple, complete the short onboarding wizard (around 3 minutes), and the platform will map your services to the regulated service definitions. You will know exactly which parts of your business are in scope and what you need to do next.

Prefer to read through it first? Here is the full picture.

General information only. This article describes regulatory requirements under the AML/CTF Act 2006 (as amended) and AUSTRAC guidance. It is not legal or compliance advice. For guidance specific to your agency, consult a qualified AML/CTF compliance professional. Information current as of May 2026 - confirm with AUSTRAC for binding guidance.

Why this question matters now

Most agency principals understand that AUSTRAC Tranche 2 is coming and that it affects real estate. What fewer have mapped out is exactly which roles and services inside their agency are caught - and which are not.

Getting this wrong in either direction is a problem. Assume your PM team is out of scope when they are not, and you leave a compliance gap. Assume everything is in scope when it is not, and you spend time and money building compliance infrastructure you do not need.

The AML/CTF Amendment Act 2024 brought Australian real estate agencies into the regulatory framework. The obligations take effect from 1 July 2026, under the AML/CTF Act 2006. Understanding the scope of those obligations starts with the definition of a "designated service."

What triggers the obligation: designated services

Under the AML/CTF Act 2006 (as amended), a "designated service" in the real estate sector means services provided to a buyer or seller in a real estate transaction - specifically, services to facilitate the acquisition or disposal of real property.

That is a precise definition. It is worth reading carefully.

What it captures:

Listing and selling residential property on behalf of vendors
Buyer's advocacy services (representing a purchaser in a transaction)
Selling commercial or industrial property on behalf of vendors
Rural property sales

What it does not capture:

Leasing residential property (entering into or managing a tenancy agreement)
Property management where no sale is involved
Rental appraisals with no transaction component
Strata management

The dividing line is the transaction. If the service facilitates someone buying or selling property, it is regulated. If it does not, it is not.

The property management question

For a pure-play property management agency - one that only leases, manages, and renews tenancies - the answer is straightforward: that business is not a reporting entity under Tranche 2 and has no AUSTRAC obligations under the new rules.

This catches a lot of principals by surprise. The AML compliance conversation in the industry has been dominated by sales agents, and the impression has formed that everyone in real estate is affected. That is not accurate.

Property management is out of scope if:

The business only provides leasing and management services
No part of the business facilitates property sales transactions
Staff do not act as buyer's or seller's representatives in acquisitions or disposals

However, there are three situations where PM functions can create obligations:

1. The mixed agency

If your agency does both PM and sales, the sales function creates the reporting entity obligation. You do not get to ring-fence the sales team and exempt the rest. Your agency as a whole is a reporting entity, and your AML/CTF program must address the regulated services - even if PM staff never touch a sales file.

This does not mean PM staff need extensive AML training or that rental files need the same CDD scrutiny as a sales transaction. Your program should reflect the actual risk and exposure of each service. But the entity-level obligation applies.

2. PM involvement in sales

In some agencies, property managers are involved in selling tenanted properties - liaising with buyers, facilitating inspections, providing tenancy information to support the transaction. If that involvement crosses into "facilitating the acquisition or disposal," those individuals may be providing a designated service.

This is worth discussing with a compliance professional if your agency operates this way. The boundary is fact-specific.

3. Commercial management with transaction components

Commercial property management sometimes includes advising owners on sale or lease transactions, or acting on their behalf in negotiations. If those services involve facilitating a sale, they are in scope regardless of how the role is labelled.

What obligations apply if you are in scope

If your agency provides designated services - even just the sales function - you must, from 1 July 2026:

Enrol with AUSTRAC (if you have not already done so) via AUSTRAC Connect. This is a one-time step.
Have a written AML/CTF program in place before providing a designated service. The program must be based on a risk assessment specific to your business, cover the required components, and be approved by senior management.
Conduct customer due diligence (CDD) on clients connected to property transactions - verifying identity, understanding the nature of the transaction, and assessing risk.
Screen clients against sanctions lists and for politically exposed person (PEP) status.
Report suspicious matters to AUSTRAC when required.
Keep records for seven years.

For the full list of obligations and what each involves, see our guide to what AUSTRAC Tranche 2 means for real estate agents.

The fast path for mixed agencies

If your agency does sales and property management, here is the most efficient way to get the sales function compliant without over-complicating the PM side.

Step 1: Sign up and set up your agency profile (around 2 minutes) At AML Simple, enter your ABN and the platform pulls your registered business details from the Australian Business Register automatically. You select which services you provide - the wizard includes the Tranche 2 service definitions so you can map your actual operations.

Step 2: Complete the AUSTRAC Enrolment Cheat Sheet (around 5 minutes) Open AUSTRAC Connect in one tab and the Enrolment Cheat Sheet in another. Every field AUSTRAC needs is pre-filled from your account. Copy-paste down the form. Done.

Step 3: Run the AML/CTF Program Generator (around 15 minutes) The wizard asks the right questions about your agency - your services, your customer types, your risk profile. It produces an AML/CTF program consistent with AUSTRAC's own Program Starter Kit structure.

At the end of Step 3, your agency is enrolled, your program is built, and your compliance record-keeping has started. That is the hard part done.

One program or two?

A common question from principals of mixed agencies: do we need a separate AML/CTF program for the sales function, or does one program cover the whole agency?

One program covers the whole agency. An AML/CTF program is an entity-level document - it belongs to the reporting entity (your agency), not to a department or service line. The program must address the designated services your agency provides and the risks associated with them. PM operations that do not involve designated services do not need their own program; they sit outside the program's scope by definition.

What good programs do is clearly define which services are in scope and which staff roles interact with those services. This makes the program accurate and auditable without creating unnecessary complexity for the PM side of the business.

The enrolment deadline

AUSTRAC's enrolment portal (AUSTRAC Connect) is open now. There is no deadline to enrol before 1 July 2026, but you cannot legally provide a designated service after that date unless you are enrolled and your program is in place.

Practically, this means enrolment should happen in the weeks before July - not the day before. The process itself is straightforward, but allowing time for any administrative issues is sensible.

If your agency is part of a franchise network, check with your network whether they are handling group enrolment or whether each office needs to enrol individually. Most networks are treating each franchisee as a separate reporting entity, but confirm this with your franchisor.

Frequently asked questions

Our office does 80% property management and 20% sales. Are we still a reporting entity?

Yes. If any part of your business provides designated services (sales), the agency as a whole is a reporting entity. The proportion of revenue from PM vs sales does not affect this. Your AML/CTF program should be proportionate to the risk and scale of the designated services, but the obligation exists from the first sales transaction.

Do property managers need to complete AML training?

If property managers have no involvement in sales transactions and never interact with the designated services side of the business, they are not required to complete AML/CTF training under the Act. However, many agencies train all staff at a general awareness level so that anyone who does encounter a suspicious transaction or inquiry knows how to respond.

We have a separate PM company and a separate sales company. Does each need its own program?

Each legal entity that is a reporting entity needs its own AML/CTF program. If they are genuinely separate companies providing separate services, they are separate reporting entities. If the arrangement is primarily administrative and the business is effectively one operation, that is a question for a compliance professional.

Can property managers conduct inspections for buyers without triggering the obligation?

The key question is whether the service constitutes "facilitating the acquisition" of real property. A PM showing a tenanted investment property to a potential buyer on behalf of the selling agent is probably not independently providing a designated service - but if the PM is effectively acting as the agent for the transaction, that assessment changes. Get specific advice if this is a regular practice in your agency.

What happens if we only do residential leasing and the rules change?

The current Tranche 2 legislation as passed does not include residential leasing as a designated service. AUSTRAC has indicated it may expand the regime over time, but that expansion would require additional legislative change. For now, pure leasing is out of scope. Monitor AUSTRAC's guidance for any updates.

What to do next

If your agency provides any sales services, start here:

Check your scope - sign up at AML Simple and complete the 3-minute onboarding wizard
Enrol with AUSTRAC via AUSTRAC Connect
Build your AML/CTF program using the Program Generator

For the full picture of what Tranche 2 means for your agency, read our AUSTRAC Tranche 2 complete guide.

Compliance does not need to be complicated. For most small agencies, the path from zero to compliant is a few hours of focused work - not weeks of consultant engagement.