For as long as most property managers have been in the industry, trust account compliance has meant one thing: state-based legislation like the Property and Stock Agents Act in NSW, the Estate Agents Act in Victoria, or the Agents Financial Administration Act in Queensland. Separate the funds, receipt correctly, reconcile monthly, get audited annually. That has not changed.
What has changed is that a second, federal layer of regulation now sits on top of it. From 1 July 2026, real estate professionals become reporting entities under Australia’s Anti-Money Laundering and Counter-Terrorism Financing regime, commonly known as Tranche 2. If your agency receives or holds trust money, this now applies to you, in addition to everything your state regulator already requires.
What Tranche 2 actually asks of you
At a practical level, three things:
Customer due diligence. You need to verify who you are dealing with, both landlords and tenants, before and during a tenancy relationship. This includes basic Know Your Customer checks that many agencies previously only did informally.
Ongoing monitoring. Rather than a one-off check at the start of a relationship, you are expected to keep an eye on transaction patterns and flag anything that looks out of step, such as unusual payment sources or large cash transactions.
Suspicious matter reporting. If something does not add up, you have an obligation to report it to AUSTRAC, Australia’s financial intelligence agency.
Agencies also need to enrol with AUSTRAC and put a documented AML/CTF program in place, covering a risk assessment and the policies that support it.
Why this sits so close to trust accounting
The overlap with trust accounting is not a coincidence. Trust money is, by definition, someone else’s money moving through your systems, which is exactly the kind of flow that AML regulation exists to watch. The good news is that if your trust accounting is already well run, with accurate receipting, clear ledgers, and clean records tying every dollar back to a person and a property, you already have most of the raw material an AML/CTF program needs. Agencies with messy, manual trust processes have considerably more work to do here, because they are effectively building both systems from a standing start at the same time.
What to do between now and 1 July
A few practical steps make this far less daunting:
- Map your money flows. Know exactly where funds enter your trust account, from whom, and for what purpose. This is the foundation of any due diligence program.
- Audit your current KYC habits. Most agencies do some version of this already for new landlords and tenants. The gap is usually consistency and documentation, not a total absence of process.
- Talk to your auditor early. Your existing trust account auditor is a natural first point of contact, since they already understand your business and can help you scope what a proportionate AML/CTF program looks like for an agency your size.
- Get your record-keeping trust-account-grade. If your reconciliations, receipting, and ledger notes are already clean and auditable, layering AML documentation on top is a matter of adding fields, not rebuilding from scratch.
The upside of getting ahead of it
Agencies that treat this as a compliance afterthought tend to find it lands as a scramble in June. Agencies that treat trust accounting and AML readiness as one connected system, rather than two separate headaches, generally find the new obligations slot in with far less disruption. It is also a reasonable moment to ask whether your current trust accounting setup, whatever platform it runs on, actually gives you the clean, exportable transaction history that both your state regulator and AUSTRAC are going to want to see.
If you would like help mapping where your agency stands against the July 2026 deadline, or simply want a stronger trust accounting foundation before AML obligations layer on top, Trust Account Solutions can help you build both at once.