120 Days Left — Why Every Property Buyer in Australia Needs to Prepare Now | APS133

120 days. That’s all you’ve got. On July 1st, 2026, every single person involved in your property purchase — your agent, your lawyer, your accountant, even the developer selling you the house — they all become anti-money laundering inspectors. Where your money came from, who’s behind your trust, whether your funding trail is clean — all of it gets checked. So here’s the real question: can your money handle that level of scrutiny?

Today I’m covering 3 things. First — what this law is and why Australia was forced to act. Second — who’s checking you and how, including a part almost nobody knows about. Third — what you can no longer get away with, and what’s still on the table.

18 Years of Looking the Other Way

In 2006, Australia passed its anti-money laundering law — Tranche 1. It covered banks, casinos, and remittance companies. Real estate agents? Not covered. Lawyers? Not covered. Accountants? Not covered. For 18 years, these three industries were a regulatory blind spot. Let that sink in.

The Financial Action Task Force — FATF — came to inspect in 2015 and rated Australia “non-compliant” on four core recommendations. Only five FATF members hadn’t regulated these industries, and Australia was standing right alongside Haiti and Madagascar. A G20 member, ranked with some of the poorest countries on Earth.

But it gets worse. The IMF modelled that if Australia hit the FATF grey list, capital inflows could drop by 7.6% of GDP. You don’t even need to be on the list — just the rumour is enough to scare away tens of billions in cross-border investment.

A few more numbers. Australia generates $43.7 billion in criminal proceeds every year. Money laundering runs at roughly 2.3% of GDP. Since 2019, the Australian Federal Police has seized over $1.2 billion in criminal assets — and a big chunk of that was residential property. Houses have become one of the best tools for washing dirty money. That’s the reality.

So this isn’t the government with nothing better to do. On December 10th, 2024, the AML/CTF Amendment Act 2024 received Royal Assent. It takes effect July 1st, 2026 — 100,000 new reporting entities pulled into AUSTRAC’s net at once. After 18 years, the blind spot finally gets a spotlight. Now let’s get to the part that directly affects you.

Who’s Checking You

After July 1st, five industries come under AUSTRAC — the Australian Transaction Reports and Analysis Centre. Real estate agents and buyer’s agents, lawyers, accountants, trust and company service providers, and precious metals dealers. If you do business in any of these, you’re a reporting entity now.

But here’s what most people miss. Under this framework, you — the buyer, the seller, the investor — are the one being checked. The agent checks you. The lawyer checks you. The accountant checks you. And they’re not just verifying your name — they’re tracing where your money came from and who really controls the structure behind you.

Now here’s the part that almost nobody is talking about. Developers and builders are also reporting entities. The new law added Table 5 under Section 6. The first part covers agents — some people know that. The second part targets sellers who sell directly without an independent agent. The most obvious examples? Developers handling their own sales, and builders selling house-and-land packages. AUSTRAC’s website says it plainly — anyone selling house-and-land packages, off-the-plan apartments, or new development lots is now a reporting entity.

What does this mean? Say you want to buy a house-and-land package. Before July 1st, it was simple: deposit, contract, wait for the build. After July 1st, the developer checks you before you even sign — who you are, where the money’s from, and if you’re buying through a trust, who the beneficiaries are. Can’t answer? No contract.

And it gets layered. Developer selling direct? They check you. Through an independent agent? The agent checks you. Through in-house sales? Still the developer. And your lawyer and accountant run their own checks on top of that. Before, you dealt with your agent and lawyer. Now your upstream — the builder, the developer — they’re in the game too.

This is exactly why VISION Gold Membership starts with KYC — Know Your Customer — preparation. The agent checks you, the lawyer checks you, the developer checks you. If you’re not ready, you get stuck on contract day and the deal stalls or dies. Compliance isn’t a signing-day problem — it’s a day-one problem.

Quick run-through of the obligations: all reporting entities must register with AUSTRAC — registration opens March 31st, takes effect July 1st, deadline July 29th. For every client: identity verification, Ultimate Beneficial Owner identification, Politically Exposed Person screening, source-of-funds proof, suspicious activity reporting within 24 hours to 3 days, and 7-year record retention.

Penalties? Companies face up to $33 million. Individuals up to $6.6 million or 10 years in prison. Not registered? $19,800 per day for companies, $3,960 for individuals. Think AUSTRAC won’t follow through? Crown Casino — $450 million settlement. SkyCity — $67 million fine. Already done and dusted.

So now you know who checks you, what they check, and what happens if you’re not compliant. Next — what can’t you do anymore, and what paths are still open?

If you have any questions about property investment, please book a free discovery call on our website. If you want a team offering one-stop service to help you build a property investment portfolio, achieve financial freedom and retire early, join our VISION Gold Membership starting with a 30-minute discovery session. Or to keep it simple, our data-driven buyer's agency service can help. We buy and manage properties for our clients anywhere in Australia. If you have an international view, talk to us about the UAE VISION Gold Membership. We help you invest in the UAE property market, plan your tax residency, reduce your taxes to almost 0 and handle CRS/AML auditing. Links to the service are in the description below.

What You Can No Longer Get Away With

Let me draw the red lines. One by one.

Smurfing for Chinese — splitting money under the $50,000 threshold and wiring it in small batches. That’s already a suspicious transaction signal. Once flagged, your money freezes and your accounts could be shut down.

Underground banking or Hawala? No paper trail. The new law demands proof of source — if you can’t produce a bank statement, that money won’t pass KYC with anyone.

Shell companies to hide your name? The law drills down to the Ultimate Beneficial Owner—the actual person. Three layers of shells won’t help. Discretionary trusts? Even tougher — every beneficiary who received a distribution in the past three years must be identified.

Fake trade invoices? Enhanced Due Diligence cross-checks against CRS data. You report one number, the tax office sees another. It won’t match.

Crypto as a bridge? China banned all crypto trading in 2021, expanded the ban to stablecoins in February 2026. In Australia, Virtual Asset Service Providers come under AML from March 31st. Both ends are locked. No gap.

Running money through a lawyer’s trust account or wiring it to a developer? Both are reporting entities now. Every transaction gets reported to AUSTRAC.

Going through Singapore? Already 37 out of 40 FATF recommendations are compliant. After the $3 billion laundering case in 2023 — ten Chinese nationals from Fujian, all convicted — it’s only getting tighter.

What about Dubai? When the UAE came off the FATF grey list in February 2024, my first thought was actually: this place is about to get more stable. Going through the grey list forced a full compliance overhaul — 39 out of 40 recommendations now met. Here’s the pattern: the stronger a country’s compliance framework, the safer it actually is for your money.

One more — CRS 2.0 kicks in January 1st, 2027. Chinese tax authorities will automatically receive your Australian financial account data. The ATO’s latest numbers: 1.17 million China-linked accounts, $35.8 billion involved. Two-way transparency — what you do here, they see there. The same goes for UK and Canadian residents.

No grey-area havens left on Earth. But flip it around — get your compliance right, and everywhere is a safe haven. Legitimate paths still exist: SAFE-approved large transfers for migration, education, or family support; using local income as proof of income source if you already have PR; joint purchase with a citizen or PR spouse; and professional cross-border structuring within a compliant framework.

You now have the full picture of AML Tranche 2. But if you’re a foreign buyer (non-resident) of Australian properties, the next section matters most.

Three Layers of Scrutiny

You’re not facing one layer of AML. You’re facing three, all at once.

Layer one — FIRB. The ban on foreign buyers purchasing existing properties runs until March 31st, 2027. Even temporary visa holders can’t buy.

Layer two — AML Tranche 2. Source of funds, trust beneficiaries, company structures — everything traced to the real person.

Layer three — CRS 2.0. Automatic financial account data exchange among the OECD countries. Your bank accounts, rental income, and investment returns — your country of tax residence tax authorities receive it all.

All three together mean this: every property transaction you make in Australia is legally transparent. Australia checks if your money is clean. Other countries check if you’ve paid tax on it.

If you’re already in Australia with PR or citizenship, FIRB doesn’t apply — good news. But AML plus CRS still do. Holding through a trust or company? The beneficial owner must be traced to a natural person. Discretionary trusts require identifying every beneficiary who received distributions in the past three years. If you used creative methods to bring your deposit across, that money could now come under review.

So you’ve got to pull together all source-of-funds documentation now. Review your trust and company structures — can they hold up? And if there are past issues, get a professional involved today, not on settlement day.

For those overseas with Australian property, being overseas doesn’t protect you. It’s the opposite. Your property is here. Your agent, lawyer, and accountant are here. After July 1st, they all report to AUSTRAC. Your rental income gets shared with your home country’s tax authorities via CRS. Since early this year, overseas investors have already started selling inner-city apartments in Sydney and Melbourne — some bought years ago and barely broke even. Cashing out before July 1st might be their smartest exit.

Incomplete documentation? Problems will surface next time you sell or settle. If you’re not in Australia, you need someone watching your compliance even more.

Most analysts say AML creates friction but won’t crash prices. The off-the-plan market gets hit hardest. Speculative overseas money that can’t explain itself won’t get through the door. Over time, buyer profiles will shift from speculative foreign investors to owner-occupier migrants.

Do These Three Things Now

Special thanks to this episode’s professional information contributor — Bluewealth Advisory. They specialise in cross-border wealth infrastructure, AML auditing, and CRS compliance. Their team includes licensed tax agents, compliance lawyers, and CRS specialists. They don’t help you hide — they stand in the tax auditor’s shoes, building your structure so that when the knock comes, every dollar and every account makes sense. Core services include UAE tax residency planning, asset holding structure design, cross-border income compliance, and annual CRS reviews. We’ve brought Bluewealth Advisory into our Gold Membership — now six expert partners — building the most trusted brand in Australian property investment. Find the link in the description or message us to learn more.

AML Tranche 2 is the biggest financial regulatory expansion in Australia in nearly 20 years. From July 1st, agents, lawyers, accountants, developers, and builders all come under AUSTRAC. Where your money comes from — you need to explain it.

Three things to do right now. First — start collecting source-of-funds documentation today. Bank statements, transfer records, payslips — everything you can find. Second — review your trust and company structures. Can they survive the double scrutiny of AML plus CRS? Third — don’t wait for July 1st. Get a professional compliance review. The earlier you act, the cheaper and safer it is.

Here’s the only line you need to remember: from 2026, it’s not who buys the most that wins. It’s not who buys the cheapest. It’s who buys compliantly. Get the structure right, and no law can touch you.

Watch the video version of the blog on YouTube.

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