Is rent-roll work captured by Tranche 2?

Not as rent-roll work. Collecting rent, managing tenancies and paying a landlord's outgoings are not brokering a sale, purchase or transfer of real estate (s 6, table 5, item 1). Handling rental income and expenses through a trust account is also excluded from the professional-services item that covers holding and managing other people's money (s 6(5C)(f); Class Exemptions Rules s 2.1). AUSTRAC's CEO has said agents won't have obligations in relation to the rental properties they manage.

What if my agency does both rentals and sales?

The legal entity that brokers sales is a reporting entity and must enrol. Its AML/CTF obligations attach to its designated services. CDD applies to the customers of those services (s 28). The risk assessment covers the risks you face in providing them (s 26C(1)). Your programme must suit the nature, size and complexity of your business (ss 26C(2), 26F(1)(c)). Landlords and tenants do not become CDD customers because you manage their property. A landlord who asks you to sell does.

Is commercial leasing a designated service?

Usually not. A lease for a term of 30 years or less, not counting options for further terms, is excluded from the definition of real estate (s 5). A longer lease is real estate; AUSTRAC's examples include 99-year leases in the ACT and crown and pastoral leases. If you broker the grant or assignment of a lease of more than 30 years, get advice. The interest is real estate, but the guidance we have reviewed does not say directly whether brokering the grant of a new lease is brokering a 'transfer'.

Does property management need to comply with AUSTRAC?

Whether property managers and leasing agents are captured by Tranche 2, what the exclusions actually cover, and how obligations work in an agency that also sells.

In short

Pure property management is outside the AML/CTF regime. Managing tenancies is not brokering a sale, purchase or transfer of real estate. A lease of 30 years or less is not 'real estate' under the Act, and handling rent through a trust account is expressly carved out. An agency that also sells is a reporting entity, but its obligations attach to its designated services, so the rent roll does not turn landlords and tenants into CDD customers. A lease of more than 30 years is real estate, so brokering one may be in scope.

Property management on its own is outside Tranche 2. A business that only leases properties, collects rent and manages tenancies does not provide a real estate designated service and has no AML/CTF obligations for that work.

Why it is excluded. Three parts of the AML/CTF Act 2006 (Cth) work together.

It isn't brokering a sale, purchase or transfer. The real estate designated service is brokering the sale, purchase or transfer of real estate (s 6, table 5, item 1). Managing a tenancy is none of those.
Ordinary leases aren't "real estate". The Act's definition of real estate includes leasehold interests in general, but excludes a lease for a term of 30 years or less, not counting options for further terms (s 5).
Handling rent money is carved out. A separate designated service covers receiving, holding and managing a person's money as part of a transaction (s 6, table 6, item 3). Section 6(5C)(f) and s 2.1 of the AML/CTF (Class Exemptions and Other Matters) Rules 2007 exclude rental income and expenses managed by a real estate agent through a trust account. AUSTRAC's guidance on professional services confirms that exclusion.

AUSTRAC's CEO put it plainly to the REIQ conference in October 2025: property management services, "such as residential and most commercial leases", are excluded, and agents "won't have obligations in relation to rental properties" they manage.

What is in scope. Any work that brokers a sale, purchase or transfer of real estate is in scope, whether or not the same business runs a rent roll:

residential and commercial sales;
buyer's agency;
auctions where you act for the seller;
off-the-plan and project sales that you broker.

Leases of more than 30 years. A lease longer than 30 years is real estate under s 5. AUSTRAC's examples include 99-year leases in the ACT and crown and pastoral leases. Brokering the sale or assignment of such an interest may be a designated service. Whether brokering the grant of a new long lease counts as brokering a "transfer" is not settled in the guidance we have reviewed, so get advice before you take one on.

Agencies that do both. If the same legal entity sells as well as manages, it is a reporting entity because of the sales work, and must enrol and run an AML/CTF programme. But the obligations are tied to the designated services it provides.

CDD applies to the customers of a designated service (s 28). For a sale, that means the seller and the buyer.
The risk assessment covers the risks you may reasonably face in providing your designated services (s 26C(1)).
Your programme must suit the nature, size and complexity of your business (ss 26C(2), 26F(1)(c)).

A landlord or tenant does not become a CDD customer because you manage the property. A landlord who instructs you to sell the property does.

You do not need a separate company to keep property management outside the regime. The trust-account exclusion applies to the rental work whatever else the agency does.

What to do next. List every service your business provides and mark which ones broker a sale, purchase or transfer of real estate. If any do, the entity is a reporting entity, so make sure it is enrolled and its programme covers those services. Flag any lease longer than 30 years for advice.

Up next · Does It Apply To You?

Buyer's agents and AUSTRAC — what you need to know

Whether buyer's agents are captured by Tranche 2, what obligations apply, and how the workflow differs from a seller's agency.

Frequently asked questions

Is rent-roll work captured by Tranche 2?: Not as rent-roll work. Collecting rent, managing tenancies and paying a landlord's outgoings are not brokering a sale, purchase or transfer of real estate (s 6, table 5, item 1). Handling rental income and expenses through a trust account is also excluded from the professional-services item that covers holding and managing other people's money (s 6(5C)(f); Class Exemptions Rules s 2.1). AUSTRAC's CEO has said agents won't have obligations in relation to the rental properties they manage.
What if my agency does both rentals and sales?: The legal entity that brokers sales is a reporting entity and must enrol. Its AML/CTF obligations attach to its designated services. CDD applies to the customers of those services (s 28). The risk assessment covers the risks you face in providing them (s 26C(1)). Your programme must suit the nature, size and complexity of your business (ss 26C(2), 26F(1)(c)). Landlords and tenants do not become CDD customers because you manage their property. A landlord who asks you to sell does.
Is commercial leasing a designated service?: Usually not. A lease for a term of 30 years or less, not counting options for further terms, is excluded from the definition of real estate (s 5). A longer lease is real estate; AUSTRAC's examples include 99-year leases in the ACT and crown and pastoral leases. If you broker the grant or assignment of a lease of more than 30 years, get advice. The interest is real estate, but the guidance we have reviewed does not say directly whether brokering the grant of a new lease is brokering a 'transfer'.

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