Anti-Money Laundering and Counter-Terrorism Financing Act 2006 now applies to Real Estate, Strata Managers who manage Company Title Schemes.

New reforms that took effect from 1 July 2026 have expanded the professional services covered under the amended Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) framework, with oversight by AUSTRAC.

In simple terms, the changes mean that many strata and real estate businesses now have similar anti-money laundering obligations to banks, lawyers and other professional service providers.

How it applies to Real Estate Agents

If a real estate agency provides a regulated (“designated”) service, it must now:

• Know who its clients are by verifying their identity before acting for them.
• Assess the risk that a client or transaction could involve money laundering or terrorism financing.
• Ask questions about unusual transactions, such as where funds have come from if circumstances appear suspicious.
• Keep records of identity checks and other required information.
• Report suspicious matters to AUSTRAC where required. Importantly, the agency cannot tell the client that a suspicious matter report has been made.
• Have an AML/CTF compliance program, train staff and appoint someone responsible for compliance.

What this means for buyers and sellers

Clients should expect to be asked for:

• Photo identification (passport or driver’s licence).
• Proof of address.
• Information about companies, trusts or beneficial owners if they are purchasing through an entity.
• In some higher-risk cases, information about where the purchase funds originated.

For most ordinary residential transactions, the additional requirements are simply more identification and record-keeping.

What about Strata Managers?

This is where there is an important distinction.

Most strata management services are not designated services under the AML/CTF Act simply because they are strata management. A strata managing agent collecting levies, arranging repairs, paying invoices and administering an owners corporation is generally not automatically captured by the new Tranche 2 reforms.

However, a strata management business may become subject to the Act if it also provides a designated service, for example through a separate real estate agency business that:

• sells property,
• acts as a buyer’s agent,
• or provides another regulated real estate service.

What about Company Title Management?

Many NSW Strata firms provide not only strata management services for Strata schemes but also Company management.

In mid 2026, the SCA Australasia, together with the Real Estate Institute of Australia (REI), reached out to the Minister for Home Affairs, The Hon Tony Burke MP, to seek further clarity on whether strata managers will be captured as part of the new real estate services definition under the Federal Government’s AML/CTF reforms.

REI have advised that strata managers will not be captured under the definition of real estate designated services as they only attach to:

• brokering the sale, purchase or transfer of real estate on behalf of a buyer, seller, transferee or transferor in the course of carrying on a business, or
• selling or transferring real estate in the course of carrying on a business selling real estate, where the sale or transfer is not brokered by an independent real estate agent.

SCA (NSW) understands that some member businesses offer additional services with regards to company title arrangements which could potentially be captured under the new Professional Designated Services definition, including:

• Recording the agent’s business premises as the registered office address on ASIC records, and
• Appointing a senior employee of the agent (licensee in charge or similar) as company secretary.
• Appointing an employee of the agent as a director of the company on title, and
• Appointing an employee of the agent as a nominee shareholder of the company on title.

A Structured Path Forward

Managers who offer Company Title Management in their businesses may need to:

1. Enrol with AUSTRAC by the 29 July 2026 (where required).
2. Implement an AML/CTF program.
3. Train staff.
4. Introduce customer identification (KYC) procedures.
5. Establish processes for monitoring, record keeping and reporting suspicious matters.

For a business like Strata Real Estate Services, the AML/CTF obligations may apply to our Company Title Management transactions without extending to your day-to-day strata management functions.

Unfortunately, this will impose additional management cost on Company Title Schemes.

Further clarification is required from Government which will come from the SCA Australasia.  When received we will forward that advice to those many company title scheme we manage (some we have managed for over 50 yrs).

However come 28 July 2026, if this issue is still unclear we will be required to enrol all Company Title Schemes with AUSTRAC by the 29 July 2026. 

In these times of every changing regulation, we continue to provide a clear, low-disruption pathway to improved governance, compliance and operational performance.

Your Building, Our Expertise.