Australia’s property industry is undergoing a major regulatory transformation. While real estate deals have long been known worldwide as a favoured channel for money laundering, the local industry has operated chiefly outside of strict Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws—until now. The Federal Government is now acting to close these regulatory loopholes, meaning agents and professionals, especially in active markets like Perth, will soon face new expectations around compliance, transparency, and accountability.

This is particularly important for Perth, where property demand has surged thanks to population growth, interstate arrivals, mining sector growth, and homes being more affordable than in the eastern states. However, these advantages also increase risk. Large transactions, money flowing in from other states and overseas, complicated ownership setups, and private sales can all make it easier for illegal financial activities to go unnoticed. Regulators fully recognise these risks, and the property sector is now a key focus for them.

Money laundering is no longer just a concern for banks and financial institutions. With the introduction of the Tranche 2 AML/CTF reforms, real estate agencies, buyer’s agents, developers, conveyancers, and lawyers involved in property deals will become ‘reporting entities’ and must meet new legal requirements. These include verifying client identities, monitoring transactions, reporting anything suspicious, and keeping thorough records. There are harsh financial and reputational penalties for failing to comply.

Property is especially appealing to those looking to launder dirty money—it lets people shift large sums in one go, offers the chance to grow wealth, and can hide the actual owners through trusts, companies, or layered arrangements. In Perth, the risks are higher due to common off-the-plan projects, mining investments, and buyers from other states. Regulators often single out WA for extra attention, given its record of organised crime, overseas money laundering, and property-related assets.

It’s important to note that these stricter AML rules aren’t meant to slow down genuine property transactions or unfairly burden honest professionals. The real goal is to bring Australia in line with international benchmarks, such as those set by the Financial Action Task Force (FATF). For a long time, Australia has been criticised for allowing key professions, such as real estate, to operate outside the AML system. These reforms aim to address those shortcomings, safeguard the integrity of the property market, and prevent real estate from being used for criminal purposes.

This blog will unpack what more burdensome AML regulations mean for Perth’s property sector, translating complex legal changes into practical insights for businesses. Instead of seeing compliance as a hurdle, this blog positions it as a valuable tool for managing risk, protecting your reputation, and ensuring long-term business health.

Understanding Money Laundering – A Global and Australian Perspective

1. To grasp why authorities are increasing oversight of the property sector, it’s essential to understand what money laundering is, how it operates globally, and why real estate—especially in places like Australia—has become a significant focus of regulatory change. For those working in Perth’s property industry, this understanding is now a must. It underpins both risk awareness and the need to meet new compliance standards.

2. Put simply, money laundering is about hiding the origins of illegal funds, so they appear legitimate. Worldwide, it’s believed that criminals generate trillions of dollars each year from things like drug dealing, fraud, online crime, tax dodging, and organised criminal activities. By laundering this money, offenders can move it into the mainstream economy and use it without drawing attention.

3. Globally, money laundering typically proceeds through three main phases: placement, layering, and integration. Placement refers to the introduction of illegal funds into the financial system, often through businesses that handle large amounts of cash. Layering is about making the source of the money more challenging to trace—this can involve complex transactions or the purchase of assets.

4. Integration is the final step, when the money comes back into the economy looking clean. Property is a popular choice for laundering at the layering and integration stages, as real estate deals can absorb large amounts of cash and retain value over time. Around the world, authorities have responded by strengthening anti-money laundering (AML) rules, focusing primarily on professions known as ‘gatekeepers’—like lawyers, accountants, real estate agents, and trust providers.

5. These jobs handle significant transactions but, in the past, haven’t always faced harsh AML scrutiny. Nations such as the UK, Canada, and EU member states already impose strong AML requirements on property professionals. Until lately, Australia has stood out by not doing the same.

6. In Australia, anti-money laundering and counter-terrorism financing (AML/CTF) rules have mainly applied to banks, financial firms, casinos, and money transfer services. These businesses conduct detailed customer checks and closely track transactions, but property sales have mostly slipped under the radar.

7. Criminals could get around tight banking rules by buying property and working with professionals who weren’t obliged to check where the money came from or who really owned the assets. International organisations have regularly criticised this lack of regulation. The Financial Action Task Force (FATF), which sets the global standard for AML, has often highlighted Australia’s failure to properly oversee real estate and related industries as a serious risk.

8. In response, the Australian Government has promised long-awaited changes through the AML/CTF Amendment package, known as ‘Tranche 2’. For Perth and the rest of WA, these changes are significant. WA’s economy has traditionally relied on resources, big economic swings, and considerable investment from both interstate and overseas. If not managed carefully, this makes it easier for money launderers to use local assets to hide funds.

9. Property in fast-growing areas, city developments, and upmarket suburbs is particularly appealing thanks to high prices and strong capital growth potential. Complex ownership structures also increase the risk. Trusts, shelf companies, family structures, and offshore arrangements aren’t illegal in themselves, but they can be used to hide who really owns a property.

10. In Perth, many investors use trusts for valid tax or asset protection reasons, so it’s crucial to assess the risks properly rather than jumping to conclusions. It’s also essential to understand that money laundering isn’t just an issue with luxury homes. Regulators now see that ordinary residential properties can be just as tempting, especially when someone buys several over time.

11. Smaller deals may not get as much attention, but can still be used to launder money. This point is especially relevant in Perth, where lower prices make it possible to buy multiple properties without raising eyebrows unless checks are in place. From a business perspective, knowing how these risks work helps agencies avoid treating compliance as a matter of fear.

12. The aim isn’t to suspect every client, but to spot warning signs or behaviours that deserve a closer look. For example, clients who don’t want to share identification, use overly complicated structures, or don’t seem to care about price or property quality may need more scrutiny. Being alert to these cues is set to become a regular part of professional practice.

How Criminals Exploit Real Estate – Mechanics, Red Flags, and Transaction Structures

1. Property itself isn’t naturally susceptible to money laundering, but certain features of property deals can appeal to those seeking to launder dirty money. For Perth’s property professionals, it’s essential to know how real estate can be misused—not to turn them into investigators, but to spot warning signs and use proper safeguards.

2. As anti-money laundering rules become stricter, this hands-on knowledge will be key to staying compliant and safeguarding agencies from regulatory trouble and reputational damage. A primary reason criminals turn to property is that it allows them to move considerable sums at once. Unlike banks, where large deposits might set off alarms, property deals naturally involve large sums.

3. In Perth, where house prices are more affordable than in Sydney or Melbourne, offenders can buy several homes over time, spreading their risk but still laundering money effectively. A typical way to exploit real estate is by using a process called layering during property purchases. Dirty money might travel through numerous accounts, companies, or even countries before it’s used to buy property.

4. By the time the deal reaches the agent, the funds may appear to come from a legitimate business, a trust, or another person. If proper checks aren’t done, the hidden risks might go unnoticed. Another common tactic is to set up complex ownership arrangements. Properties might be bought using trusts, private companies, partnerships, or even overseas organisations.

5. While these setups are often above board, they can also hide who really owns the property. In Perth, many investors use trusts for tax or asset protection, so distinguishing between standard practice and attempts to hide ownership can be tricky.

​6. Payments from third parties are another risk area. Sometimes, the person buying the property isn’t the one supplying the money—funds might come from family members, business partners, or even overseas accounts with little explanation. Although there are sometimes genuine reasons for this, it’s considered a warning sign in anti-money laundering checks, especially if combined with other odd behaviour.

7. Off-market sales or private deals can also be misused. These transactions often have less visibility, less advertising, and are wrapped up quickly. In Perth’s busy suburbs, where demand is high, off-market sales are happening more often. While they can be good for business, they need closer attention since the lower level of scrutiny can leave them open to abuse.

8. A further method is quickly selling—also known as ‘flipping’—properties. Someone might buy and resell a home quickly, sometimes for more or less than its actual value, to make it appear they’ve made or lost money legally. In Perth’s growing market, this can seem normal, so it’s essential to check carefully for anything unusual.

9. Buyers who deal mainly in cash are less common now because of tighter banking rules, but they’re still a risk if large deposits or settlements come from odd sources. Even if the money is transferred electronically, it might come from businesses that handle large amounts of cash—industries often linked to money laundering. Agents don’t need to dig through all the finances, but recognising these patterns matters more than ever.

10. It’s also important to watch for certain behaviours. Clients who avoid giving ID, push for a quick sale without a good reason, or don’t seem to care about the property’s details, value, or location may deserve a closer look. Usually, genuine buyers and sellers take an active interest in the process, so a lack of engagement can be a subtle but essential warning sign.

11. For agencies in Perth, like Bargoti Real Estate, it’s vital to remember that risks rarely appear on their own. Most dodgy deals involve a mix of warning signs, not just one. For example, buying through a trust isn’t a problem by itself, but if the trust is funded by someone overseas and there’s a rush plus little paperwork, it’s worth raising under upcoming AML rules.

The Evolution of AML/CTF Regulation in Australia – How We Got Here

1. To understand why property professionals now have direct anti-money laundering responsibilities, it’s helpful to look at how Australia’s AML laws have developed—and why real estate was left out for so many years. For those working in Perth’s property sector, this background sheds light on both the changes happening now and the reasons behind the regulator’s current push.

2. Australia’s anti-money laundering and counter-terrorism financing system began in 2006 with the AML/CTF Act. The new laws primarily focused on financial institutions such as banks, credit unions, casinos, money transfer providers, and, eventually, digital currency platforms. These organisations were seen as the main entry points into the financial system, so they were given strict rules governing customer checks, reporting, and recordkeeping.

3. Back then, lawmakers planned to introduce the rules in steps—the first part, now known as Tranche 1, covered primary financial services. Tranche 2 was supposed to follow, expanding the requirements to ‘designated non-financial businesses and professions’ (DNFBPs) like real estate agents, lawyers, accountants, and trust providers. But progress on Tranche 2 kept getting postponed.

4. This delay led to a lopsided system for almost twenty years. Banks had to check their customers thoroughly, but property professionals—who handle the most transactions—weren’t legally required to verify clients or assess AML risk. As criminals changed their tactics, moving from banks to assets such as property, this gap in the rules became increasingly problematic.

5. Pressure from overseas was a significant driver for change. Australia is a member of the Financial Action Task Force (FATF), which sets global anti-money laundering standards. FATF reports often noted that Australia’s lack of regulation for real estate and similar sectors was a significant weakness. Internationally, this made Australia look more appealing to property-based money launderers.

6. This challenge is very relevant in WA. The state’s economy—with its wealth from mining, foreign investment, and recurring waves of capital—has drawn regulators’ attention for years. Police and authorities have found that property is often used to launder criminal profits, especially when transactions involve trusts, overseas companies, or quick resales. Yet, property professionals were mainly spared from direct AML obligations.

7. The Federal Government’s new push for Tranche 2 reforms shows a broader change in approach. Instead of placing all the responsibility on banks to spot suspicious activity, regulators now recognise that frontline professionals—like real estate agents—are often better positioned to notice odd behaviour early. Agents deal directly with clients, observe how they behave, and have insight into local trends that banks don’t.

8. In 2024, new laws were passed that officially extended AML/CTF duties to more high-risk sectors, including the property industry. These changes are designed to bring Australia up to international standards and fix long-standing loopholes. While agencies still have some time to prepare, it’s now clear that these changes are locked in and can’t be reversed.

9. Looking at the Perth market, these changes are arriving at a key moment. The city is seeing ongoing demand, more investors, and a rise in buyers from other states and overseas. As more deals are done, regulators are paying closer attention. Agencies that don’t keep up could face fines, lose their good name, or miss out on clients who expect strict compliance standards.

​The 2024 AML/CTF Amendments Explained – What Has Changed and Why It Matters

1. The 2024 updates to Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws mark the most significant regulatory change for the property sector in many years. For Perth agencies like Bargoti Real Estate, these changes are very real—they shape the way property sales are handled, recorded, and overseen.

2. A key part of these changes is the long-awaited rollout of Tranche 2, which brings AML/CTF responsibilities to high-risk non-financial sectors. Now, real estate agents, buyer’s agents, property developers selling directly to buyers, conveyancers, and some legal professionals are classed as reporting entities under the law. This move puts real estate squarely within a compliance framework, once the domain of banks and other financial institutions.

3. One of the most significant shifts is that real estate work is now officially seen as a ‘designated service.’ Whether selling property, acting as a go-between, or helping with transfers, these activities now come with AML duties. It’s no longer just up to banks to spot dodgy dealings—property agencies are now seen as key players in preventing financial crime.

4. These reforms back a risk-based approach to compliance. Instead of treating every client the same, agencies need to judge risk based on who the client is, how the transaction is structured, and where the money comes from. This is especially important in Perth. For example, a local buying a family home is an entirely different risk from an overseas buyer using complex trusts or companies to purchase several properties.

5. Another major update focuses on clarifying ownership. Agencies must make genuine efforts to determine who actually owns or controls a buying entity, even if companies or trusts are involved. This matters a lot in WA, where these structures are often used for tax or asset protection. The new rules don’t ban such set-ups, but they do demand clear evidence and paperwork around who’s in charge and who benefits.

6. Checks on client backgrounds, known as Customer Due Diligence (CDD), have also been broadened. Property agencies must now confirm client identities, understand the nature of the business relationship, and consider why each transaction is occurring. Some clients—such as politically exposed persons or those with overseas funds—may need to undergo additional checks.

7. Reporting suspicious activity is another significant change. Agencies must flag deals or attempts that appear suspicious of money laundering or terrorist financing. This isn’t about accusing anyone, but about meeting legal requirements when something doesn’t add up or can’t be adequately explained.

8. On a practical level, getting prepared is crucial. Even though enforcement will be rolled out gradually, regulators have said that not being ready won’t be an excuse. The adjustment period is there so agencies can set up systems, train their staff, and make compliance part of everyday work. These changes mark a lasting transformation for real estate in Australia.

How Tranche 2 Reforms Specifically Impact Real Estate Professionals in Perth

1. Tranche 2 of Australia’s AML/CTF reforms fundamentally changes how real estate agencies operate by formally bringing them into the regulated compliance framework. While the concept of Tranche 2 has been discussed for years, the 2024 amendments finally move it from policy to practice.

2. Under Tranche 2, real estate agents are classified as reporting entities when they provide designated services. In practical terms, this includes selling residential or commercial property, acting as an intermediary between buyers and sellers, and facilitating property transactions.

3. One of the most important practical implications is that compliance begins earlier in the transaction lifecycle. AML obligations are not limited to settlement. Agencies are expected to conduct customer due diligence at the time of onboarding or when a serious intent to transact is established.

4. Tranche 2 also introduces a strong emphasis on understanding the client relationship, not just verifying identity. Agencies must assess why a client is entering a transaction, how the purchase or sale aligns with their profile, and whether the transaction’s structure makes commercial sense.

5. Another critical feature of Tranche 2 is the requirement to maintain a documented AML/CTF program. This program must outline how the agency identifies risk, conducts customer due diligence, reports suspicious matters, trains staff, and maintains records. Generic templates are unlikely to be sufficient.

6. Tranche 2 does not require real estate agents to act as investigators or law enforcement. This includes verifying identity using reliable documents, asking sensible questions where structures are complex, and escalating concerns internally when explanations are unclear or inconsistent. If a transaction raises unresolved concerns, agencies must report to AUSTRAC within the required timeframe.  

Customer Due Diligence & KYC – Setting the Right Standards for Perth Property Transactions

1. Customer Due Diligence (CDD) and Know Your Customer (KYC) checks are set to become the foundation of anti-money laundering compliance for real estate agencies under Tranche 2 changes.  In essence, CDD means verifying your client’s identity and understanding the details of their property deal.

2. For individuals, KYC usually means obtaining official ID, such as a passport or driver’s licence, and verifying it against reliable records. In Perth, with buyers often based interstate or overseas, agencies also need to think about how to collect this ID remotely. Using digital verification systems and secure online portals will help speed up the process while keeping transactions on track.

3. When dealing with companies, trusts, or other entities, the checks are more involved. Agencies must not only identify the entity but also find out who really owns or controls it—that is, the beneficial owners. In WA, trusts are often used for property investment, making this requirement especially important. Even though trusts are legal, agencies need to know who the trustees and beneficiaries are, and who actually has control.

4. It’s also vital to understand the reason and purpose behind each property deal. This doesn’t mean grilling clients, but it does involve noting why the property is being bought or sold. Is it for living in, investment, or development? Does the deal make sense given the client’s background and finances? Answering these questions helps set a foundation for risk assessment.

5. Agencies must also consider where the purchase funds come from—and, for higher-risk cases, where the client’s wealth was initially generated. For most everyday deals in Perth, this could mean checking that the funds are from a recognised bank. But when funds come from overseas, third parties, or are tied up in complicated arrangements, extra documents or further details may be needed.

6. It’s important to remember that CDD isn’t a one-off task. Agencies need to keep up due diligence throughout their business relationship with a client. This involves checking that new deals align with what’s known about the client and updating records if anything changes. For example, if someone who bought a single property suddenly starts buying several in quick succession, it could be time to review their risk profile.

7. A major challenge for agencies will be managing compliance requirements without upsetting the client experience. Buyers and sellers might wonder why so much paperwork is needed, or get annoyed by what feels like delays. Agencies that approach this well will present compliance as part of their professional practice—not a hassle.

8. Problems with CDD are a leading reason for regulatory action. If checks aren’t done properly, records are incomplete, or agencies rely too much on informal judgment, they put themselves at risk. On the other hand, agencies that follow CDD rules for every deal—no matter who the client is or how much the property is worth—will be much better protected.

Reporting Obligations – Suspicious Matter Reports and Transaction Monitoring Explained

1. One of the most sensitive and often misunderstood aspects of AML compliance for real estate agencies is reporting obligations. Under the Tranche 2 reforms, agencies like Bargoti Real Estate will be required to report certain activities to AUSTRAC—not as an accusation against clients, but as a legal responsibility designed to protect the integrity of Australia’s property market.

2. An SMR must be lodged when an agency forms a reasonable suspicion that a transaction, attempted transaction, or client behaviour may be linked to money laundering or terrorism financing. Importantly, suspicion does not require proof. It is based on reasonable grounds formed through professional judgment and observed indicators.

3. In practice, suspicion may arise from a combination of factors rather than a single issue. For example, a Perth buyer using a complex trust structure, funded by overseas third-party payments, who is reluctant to provide documentation and pushes for a speedy settlement, may trigger reasonable concern. No single factor alone confirms wrongdoing, but together they may warrant reporting.

4. SMRs must generally be submitted to AUSTRAC as soon as practicable after suspicion is formed. Agencies must also understand the strict prohibition on tipping off. This means it is illegal to inform the client—or any unauthorised party—that a report has been lodged or is being considered.

5. Another key concept is transaction monitoring. While real estate agencies are not expected to monitor financial accounts like banks do, they are expected to monitor transactions and client behaviour within the scope of their services. This includes observing changes in transaction patterns, unexplained changes in funding arrangements, or behaviour inconsistent with the client’s stated purpose.

6. Unlike banks, real estate agencies are generally not required to submit threshold transaction reports for cash transactions, as most property settlements occur electronically and cash payments are heavily restricted. However, awareness of large or unusual fund movements remains essential, particularly where deposits or pre-settlement payments raise questions.

7. A common concern among agents is whether reporting will disrupt transactions or expose the agency to legal risk. In reality, AML laws protect agencies that submit reports in good faith. Reporting does not automatically halt a transaction unless directed by authorities. In most cases, the transaction proceeds as usual, with AUSTRAC using the information for intelligence analysis.

​8. From a Perth market perspective, reporting obligations must be handled carefully to avoid unnecessary friction. Agencies should have clear internal escalation procedures so agents know whom to contact when concerns arise. This ensures that reporting decisions are consistent, documented, and not made in isolation under pressure.

9. Agents should be trained to recognise red flags and escalate concerns, rather than deciding independently whether to report. Documentation is also essential. Agencies must keep records of the information that led to suspicion, the decision-making process, and the report itself. This documentation protects in the event of regulatory review and demonstrates a proactive compliance culture.

10. One of the most significant mindset shifts for the industry is understanding that reporting is not a failure of the transaction—it is a safeguard. AUSTRAC uses aggregated data to identify patterns across markets, regions, and industries. Individual reports may seem insignificant, but collectively they help protect the property market from abuse.

Preparing for Tranche 2 – A Practical AML Readiness Checklist for Perth Agencies

As Tranche 2 AML/CTF reforms approach, property agencies in Perth—including Bargoti Real Estate—need to turn legal requirements into practical everyday actions. Proper preparation not only keeps agencies compliant but also lowers risks and helps ensure clients have a seamless experience. A clear AML readiness checklist helps agencies work through these changes. The exact steps may vary based on agency size, the kinds of transactions handled, and the types of clients served, but this framework offers a practical place to begin.

1. Registration and Governance

• Agencies need to officially register with AUSTRAC to demonstrate they offer designated services as required under the AML/CTF Act. This registration is the first move towards meeting legal standards.
• Assign a senior staff member or manager to oversee AML duties. This person must have the power, access, and responsibility needed to ensure rules are followed.
• Set out who is responsible for what, how reporting works, and who oversees compliance. Make sure top management is involved—not just frontline staff.

2. Develop an AML/CTF Program

• Develop a documented AML plan that aligns with local Perth market risks and your agency’s operating model. This should cover CDD, risk checks, reporting, record keeping, and staff roles.
• Pinpoint which clients and transaction types pose greater money laundering risks. Set out extra controls for these high-risk cases, such as enhanced due diligence.
• Integrate AML tasks into the current CRM, transaction, and document systems to keep things efficient and avoid duplication.

3. Customer Due Diligence (CDD)

• Gather ID from individuals, and for businesses or trusts, confirm the directors, structure, and who actually owns or controls them.
• Record the reason behind the property’s purchase or sale to help spot anything unusual or out of place.
• Update client files when things change, and verify that transactions still make sense given the provided reasons.

4. Staff Training

• Teach staff—including agents, property managers, and admin—about their AML duties, warning signs to look for, and how to report issues.
• Offer regular updates and refresher courses, and keep staff informed about any changes to laws or company rules.
• Use real-world situations from Perth to help staff understand what to do and to build their decision-making skills.

5. Transaction and Risk Monitoring

• Watch for signs of quick buying sprees, off-market sales, or third-party funding, and keep detailed records for later review.
• Use more thorough due diligence for politically exposed persons, overseas buyers, or clients with complex ownership structures.
• Log all findings, choices, and escalations to create a solid audit trail.

6. Reporting Obligations

• Set up clear steps for reporting to AUSTRAC if a deal seems suspicious for money laundering or terrorism funding.
• Make sure staff know not to reveal to anyone that an SMR has been submitted.
• Put in place a transparent decision-making process for handling and lodging SMRs.

7. Record Keeping and Data Security

• Store all CDD, risk checks, transaction paperwork, and reports safely in a protected system.
• Hold on to records for the time required by law, usually five years.
• Limit access to sensitive data to authorised staff only, and use secure data management methods.

8. Technology and Automation

• Employ regulatory technology tools to check identities and track who truly owns entities.
• Ensure your AML records are linked to the CRM and transaction systems for smooth operations and easier audits.
• Set up basic alerts to flag any unusual transaction patterns.

9. Continuous Review and Improvement

• Refresh your policies and procedures each year to keep up with changing laws and market developments.
• Get staff to share any problems or difficulties they have with AML procedures.
• Measure your practices against industry peers and AUSTRAC advice to stay on track.

10. Client Communication

• Clearly outline why AML checks are needed and what details will be requested.
• Let clients know about possible delays up front to keep their trust.
• Present compliance as a regular part of running a responsible, professional agency.

Penalties, Enforcement, and How Perth Agencies Can Protect Themselves

1. With Tranche 2 AML/CTF reforms now applying to the property sector, agencies need to grasp the penalties, enforcement approaches, and how to actively protect themselves. For Perth agencies like Bargoti Real Estate, being prepared and well-informed can make all the difference between running a business smoothly and facing expensive regulatory consequences.

2. AUSTRAC and other regulators hold wide-ranging powers to enforce the AML/CTF Act. Agencies that don’t comply can face not only financial penalties, but also damage to their professional reputation, such as:

• Civil Penalties: Agencies risk hefty fines if they fail to keep an AML/CTF program in place, don’t carry out appropriate customer checks, or don’t file suspicious matter reports when needed.
• Criminal Penalties: If agencies intentionally ignore their AML responsibilities, they could face criminal charges, including personal fines and even jail for those in charge.
• Enforceable Undertakings: AUSTRAC can arrange formal agreements with agencies requiring them to take specific corrective steps. While these aren’t punishments as such, they usually mean close ongoing supervision.
• Reputational Damage: Even if no fine is issued, public regulatory action can erode client trust and damage an agency’s standing—especially in Perth’s close-knit property market. This can have lasting impacts on business.

3. In the past, regulators have primarily focused on widespread failings, such as the absence of a proper AML program, poor record-keeping, or a pattern of failing to report suspicious activities. One-off mistakes are less likely to result in significant penalties if the agency can show it takes compliance seriously and acts quickly to fix problems.

4. AUSTRAC uses a risk-based, intelligence-driven enforcement approach, focusing on agencies and transactions most likely to involve money laundering. Typical reasons for audits or investigations include:

• Large numbers or high-value deals that aren’t correctly verified
• Deals that use complicated ownership arrangements or money coming from overseas
• Failing to submit suspicious matter reports regularly
• Lack of proper training for staff, or not following the agency’s own written procedures

5. Regulatory actions might start with a review of paperwork and escalate to on-site visits if any issues show up. Agencies should be ready to provide transaction records, CDD files, risk evaluations, and internal policy documents. That’s why keeping detailed records is so important.

6. Recent enforcement in WA makes it clear that most penalties come from ongoing, widespread problems rather than minor errors. Agencies with proper AML programs, clear procedures, and well-trained staff usually avoid fines—even if they make the odd mistake. Those operating in informal systems faced greater scrutiny and reputational setbacks.

7. In Perth’s market, where off-market sales, trust arrangements, and foreign investment are frequent, agencies are expected to be especially thorough. By acting now—setting up clear programs, upskilling staff, and leveraging technology—agencies can reduce regulatory risk and build greater trust with clients.

Final Thoughts – How AML Reform Will Shape Perth Real Estate

Expanding AML/CTF requirements to cover the property sector brings both hurdles and opportunities for agencies in Perth. For Bargoti Real Estate, taking the initiative on compliance goes beyond ticking regulatory boxes—it’s a smart strategy that boosts the agency’s reputation, improves how the business runs, and earns clients’ trust. With well-structured due diligence procedures, clear reporting methods, and robust AML/CTF systems, agencies can handle complex ownership structures, overseas funds, and large transactions with confidence. Embracing technology—such as digital ID checks and secure document storage—will be vital to maintaining consistent, traceable compliance while ensuring a smooth client experience.

Equally important are staff education and building a culture where compliance is second nature. Agencies that weave AML awareness throughout their business—with strong leadership, ongoing training, and practical examples—develop teams that can spot and address risks early. As Perth’s property market remains attractive to both local and overseas investors, agencies that take a thoughtful, strategic approach to AML reforms will not only stay within the law but also stand out as reliable, open, and expert players in a changing market. In an era of stricter rules, being prepared, consistent, and proactive will set the foundations for lasting success.

DISCLAIMER – The information and opinion provided is for guidance and general informational purposes only. The sole intention is to provide general understanding of the subject matter so the readers can assess whether they need more detailed information. The information provided on this website should not be regarded as a financial, business, legal or real estate advice and it is strongly recommended that the readers should seek their own independent financial, business, legal or real estate advice. While every effort has been made to ensure that the information and the material is correct and up to date at the date of publication. However, we do not guarantee or warrant the accuracy or completeness of the information provided as the factors like changes in circumstances after the time of publication, may impact such accuracy or completeness. Bargoti real estate will not accept responsibility or liability for any reliance on the blog information, including but not limited to, the accuracy, currency or completeness of any information or links.