AUSTRAC’s Tranche 2 anti-money laundering obligations have been live since July 1, and the regulator has signaled a degree of leniency in the first year as property businesses find their footing. Thousands of real estate agencies, buyer’s agent firms, and conveyancing practices have registered, ticked the first administrative box, and gone back to business as usual. John Nguyen thinks that a softer first-year posture is giving businesses a false sense of comfort.
Nguyen is the Managing Director of AML Partners, an Australian compliance firm that has grown to more than 300 clients by taking over the full scope of AUSTRAC obligations for property businesses. He spent more than a decade in AML compliance at Commonwealth Bank, Westpac, ANZ, and Suncorp, with a period at Ernst and Young. That background gave him a clear view of what happens when businesses treat compliance as a one-off task rather than an ongoing function. He says the pattern he watched inside the banks a decade ago is now repeating across the property sector.
Registration Is Not Compliance
The most common mistake Nguyen sees is a conflation of registration with compliance. AUSTRAC’s enrollment portal opened in March 2026, and the July 1 deadline gave businesses a clear administrative target. Many firms met that target. But registration is only the entry point. The substantive obligations, including maintaining a documented AML/CTF program, conducting customer due diligence on every relevant transaction, screening customers against sanctions and politically exposed persons lists, filing suspicious matter reports, and keeping detailed records, sit behind the registration step and require ongoing work.
Under the legislation passed in November 2024, companies that fail to meet these requirements face penalties of up to $33 million for corporations and $6.6 million for individuals. Criminal prosecution is possible for serious breaches. Nguyen says many of the property businesses he speaks with did not fully understand the difference between registering and complying until after July 1 had passed.
“The businesses that registered with AUSTRAC on time think the hard part is behind them. It is not. The ongoing obligations around customer due diligence, suspicious matter reporting, and staff training are where the real compliance failures will happen,” Nguyen said.
Staff Training as the Overlooked Obligation
Of all the requirements under the new regime, Nguyen identifies staff training as the one most consistently underestimated by property businesses. Every employee who handles a customer file now carries obligations under the AML/CTF Act, and they need to be trained to recognize suspicious activity, understand the reporting chain, and follow the procedures set out in the firm’s AML/CTF program.
AML Partners, which provides outsourced compliance covering program documentation, risk assessments, customer screening, identity verification, and regulatory reporting, says training is where it sees the widest gap between what businesses assume is required and what AUSTRAC actually expects. The firm says many agencies treated training as a single briefing session in the lead-up to July 1 rather than as an ongoing, documented obligation that needs to be repeated and updated as the regime evolves.
The problem is not just procedural. Nguyen points out that AUSTRAC’s framework includes mandatory independent reviews of each business’s AML/CTF program within the first three years of operation. A business that cannot demonstrate a sustained training record, with evidence that staff understood their obligations at the time of each relevant transaction, will face questions during that review.
What the First Weeks of Enforcement Are Revealing
AML Partners says its client base is roughly evenly split between buyer’s agents and real estate agents. Nguyen notes that both groups face the same core obligations, but the operational pressure feels different depending on the size and structure of the business. A large franchise network with centralized administration can distribute compliance processes across its offices. A sole-operator buyer’s agent has to manage customer screening, documentation, and training alongside the rest of their workload.
The firm reports that its pipeline of new inquiries has increased since July 1, with most coming from businesses that registered on time but found they could not sustain the day-to-day compliance workload without outside help. AML Partners’ model handles the full obligation externally, using its FlowAML software to manage onboarding, screening, risk ratings, and monitoring for each client. The firm says this approach reflects how compliance was managed inside the major banks where Nguyen previously worked, with a dedicated team responsible for the entire function rather than distributing tasks across staff who have other primary responsibilities.
Nguyen is not expecting AUSTRAC to come down hard in the next few months. What concerns him is that businesses will treat the first-year leniency as a reason to delay the real compliance work, and the gaps will catch up with them once the regulator’s approach firms up. The independent review cycle, which requires an external audit of every Tranche 2 business’s AML/CTF program within three years, will surface those gaps whether businesses are ready or not. His advice is plain: fixing a compliance program now costs less than explaining a failed review later.
