Real estate has its own designated services in Table 5. For an agency sale, both seller and buyer are customers under the Act, but their CDD timing can differ. This guide shows how the service works.
Quick answer
Sales are caught. Rent rolls are not.
For a Table 5 item 1 agency sale, the Act identifies both seller and buyer as customers. The workflow starts for each side at different points, so the timing matters.
Whether your business is a reporting entity depends on the designated services you provide — not on having an ABN or being based in Australia. Check AUSTRAC’s sector guidance, and seek professional advice for your situation.
The full guide
AML checks for real estate agents: both sides of the deal
When the checks start for vendors, buyers and buyer’s agents, how auctions change the timing, and what to keep on file.
Read itThe “Where” column shows whether each row is a designated service, an exclusion in the Act or an example from AUSTRAC’s guidance. Caught rows link to the article that covers them in full.
| The work | Caught? | Where |
|---|---|---|
| Brokering a sale, purchase or transfer of real estate | Caught | Table 5, item 1 |
| Acting as a buyer’s agent to find and secure a property | Caught | Table 5, item 1 |
| A developer selling its own stock without an independent agent | Caught | Table 5, item 2 |
| Marketing a property under a signed selling-agency agreement | Caught | Table 5, item 1 — the seller-side service has started |
| Property management and collecting rent | Not caught | No sale, purchase or transfer |
| Appraising a property for an owner who does not sell | Not caught | No transaction |
Real estate sits in its own table — Table 5 of section 6(5A) — not in Table 6 with the other professions.
The Act — s 6(5A) table 5, item 1
“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”
Customer: both: (a) the seller or transferor; and (b) the buyer or transferee. Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), s 6(5A) — table 5.
The Act — s 6(5A) table 5, item 2
“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”
Customer: the buyer or transferee. Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), s 6(5A) — table 5.
Lex-Brisbane Realty, a fictional Brisbane agency, sells Margaret Wilson’s home to David Nguyen. Sarah Mitchell, the agency’s AML/CTF compliance officer, runs the matter in the Lex-AML Organisation Workspace; Margaret and David only use the Customer Portal.
One example of how a matter in a real estate agency can run in Lex-AML, which is configured around each organisation’s own AML/CTF program. The business and its customers are fictional, the identity and screening checks use demo providers, and no real customer information is shown. The organisation makes every customer due diligence decision. Not legal advice.
In the order the Act sets them, once the business provides a designated service.
If this is work you do
Lex-AML starts by recording the designated services your firm actually provides, then helps you organise your AML/CTF program, customer due diligence and audit trail around them.
The Table 5 service that can bring real-estate agency work into the regime.
Sources
Data as at 13 October 2026.
Lex-AML supports compliance workflows and record keeping. It does not provide legal advice, does not guarantee compliance, and does not replace professional judgement or advice from a qualified AML/CTF adviser or legal professional.