Guides · Updated 23 Sept 2026

AML/CTF obligations for property developers who sell direct

When a developer sells through an agent, the agent carries the AML/CTF obligations for the brokering service. When a developer sells direct, the obligations sit with the developer.

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What is designated

Selling real estate as a developer, including off-the-plan and house-and-land, is a designated service. So is receiving deposits in connection with those sales.

What a developer needs

  • Enrolment with AUSTRAC within 28 days of the first sale.
  • An AML/CTF program covering the sales function.
  • Identification and risk rating of each purchaser.
  • Reporting of suspicious matters and cash deposits over the threshold.
  • Records for 7 years, staff training and a compliance officer.

Working with an agent

If an agent brokers the sale, the agent is the reporting entity for the brokering. Agree in writing who does what, and keep your own copy of the purchaser records you receive.

Questions people ask

We sell through a project marketing firm. Who enrols?
The firm brokering the sales is a reporting entity for that service. If you also sell direct, so are you. Check AUSTRAC guidance for your structure.

This guide is general information for real estate agents, buyers agents, property managers, not legal advice. Check AUSTRAC's current guidance for your situation.

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AML/CTF obligations for property developers who sell direct · RealtyAML