AML/CTF Rules 2025: Reporting for real estate sector

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Understanding AML/CTF Rules 2025 Part 9: Reporting, and what it means for the real estate sector

From 1 July 2026, Australian real estate agencies will need to lodge reports with AUSTRAC in certain situations. These reports are a core part of the AML/CTF framework as they help regulators spot money laundering and terrorism financing risks at an aggregate level across property transactions.

For agencies, the three most common reports will be:

• Suspicious Matter Reports (SMRs) – when something about a customer or transaction doesn’t feel right.
• Threshold Transaction Reports (TTRs) – whenever someone pays $10,000 or more in cash or equivalents, even if nothing looks suspicious.
• Annual AML/CTF compliance report - shows how your agency is meeting obligations

Suspicious Matter Reports (SMRs)

When to lodge

You must lodge an SMR if you suspect something about a client or transaction may be linked to:

• Money laundering or terrorism financing
• Sanctions breaches
• Fraud, bribery, corruption, or other serious offences
• Identity concerns (customer or agent not who they say they are)
• Unusual transactions (no clear business/legal purpose, unusually complex, or inconsistent with the client’s profile)

The suspicion can arise:

• When you’re asked to provide a service,
• While you’re providing it, or
• After the service is complete.

What to include

An SMR requires:

• Your agency details: Name, AUSTRAC ID, submission date.
• Staff details: Name, role, contact info of person lodging the report + another contact who can explain the suspicion.
• Customer details:
  • individuals (full name, DOB, citizenship, addresses, occupation, ID docs)
  • non-individuals (company/trust names, registration details, directors, beneficial owners).
• Why you’re suspicious: E.g. funds don’t match profile, beneficial owner hidden, unusual payment pattern.
• Transaction details: Property address, contract reference, settlement date, transaction value, accounts involved.
• Links to other parties: Anyone acting on behalf of the customer, related businesses, signatories, intermediaries.
• Supporting evidence: Documents, images, online records, or anything that supports your suspicion.

Examples

• A buyer with no clear income history purchases a $4m property in cash through a newly formed company. The funds come from multiple offshore accounts.
• A landlord suddenly directs rental payments to an account in a sanctioned country.
• A client repeatedly buys and flips properties between related companies at inflated values with no renovations.

Threshold Transaction Reports (TTRs)

When to lodge

You must submit a TTR whenever your agency receives cash or equivalent of AUD $10,000 or more in a single transaction - even if the transaction seems legitimate.

Relevant examples for real estate include:

• Cash deposits for property purchases.
• Rental bond or rent paid in cash over the threshold.
• Cash used to top up trust accounts.

You must lodge a report regardless of suspicion.

What to include

• Your agency details (name, AUSTRAC ID, submission date).
• Staff details (who completed the report).
• Customer details (same level as SMRs – names, DOBs, addresses, business details, beneficial owners).
• Transaction details – date, time, location, amount, foreign currency info if relevant and the kind of designated service involved i.e. buying or selling of property
• Accounts/products if involved – account numbers, opening dates, signatories, instruments (e.g. cheques).
• Purpose of the transaction (if known).

Exceptions

If cash is deposited via ATM/express deposit with no personal contact, or by a professional courier service, you don’t need to report the depositor’s details — but you must note the circumstances (e.g. “cash deposited via ATM, no personal contact”).

Real estate examples

• A buyer pays a $20,000 deposit in cash for a property.
• A tenant pays six months’ rent upfront in cash, totalling $12,000.
• An investor tops up a trust account with $15,000 cash before settlement.

Annual AML/CTF compliance reports

Each year, every reporting entity must submit a compliance report to AUSTRAC.

• Period covered: 1 January – 31 December.
• Due date: 31 March the following year (e.g. 2026 report due by 31 March 2027).
• Content: Shows how your agency is meeting obligations — AML/CTF Program in place, staff training, record-keeping, reporting, and independent reviews.
• Format: Online