7 mistakes real estate agencies are making about Tranche 2 compliance

Tranche 2 is here. Since 1 July 2026, real estate professionals providing designated services have been required to comply with Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime. That means far more than checking a client's ID.

As agencies prepare, several common misconceptions could make compliance more difficult, more expensive and more disruptive than it needs to be.

Mistake 1: Thinking it's just about identity checks

One of the biggest misconceptions is that existing Verification of Identity (VOI) processes will satisfy the new requirements. They won't.

Identity verification is only one part of the picture. Agencies must also assess customer risk, understand who actually owns the entity they're dealing with, train staff and report suspicious matters where required. Tranche 2 is about managing risk, not ticking a box.

Mistake 2: Only verifying your own client

Selling agents often assume they only need to verify the vendor. Buyer's agents assume they only need to verify the purchaser.

The law expects both sides of a transaction to be understood and verified. You cannot assume someone else has done the work.

If you do want to rely on another entity to complete verification on one side of the transaction, they must have a legal reliance agreement in place.

Mistake 3: Treating compliance as a document instead of a business process

Many agencies are focused on creating an AML/CTF policy. That's important, but it's only the starting point.

AUSTRAC expects businesses to implement their policies through everyday operations. That includes onboarding clients, documenting decisions, monitoring higher-risk matters and maintaining evidence that procedures are being followed.

A policy sitting in a folder won't satisfy AUSTRAC.

Mistake 4: Assuming one person can do everything

Many principals expect they'll simply become the compliance officer alongside running the agency. The reality is that compliance involves the entire business.

Salespeople, administrators and support staff all need to understand their responsibilities, recognise red flags and know when to escalate concerns. Without consistent training and clear workflows, important information can easily be missed.

Mistake 5: Choosing software without understanding the true cost

Many providers advertise for low or no monthly subscription fees while charging additional fees for identity verification, beneficial ownership checks, enhanced due diligence or specialist support. The subscription price is the number that gets advertised. The per-verification fee is the number that determines what you actually spend.

For an agency selling 15 properties a month, that's at least 30 individual verifications. At $8 per check that's $2,880 a year in verification fees. At $40 per check it's $14,400. Run the real numbers at your actual transaction volume before signing anything.

Mistake 6: Believing software alone solves the problem

Technology is essential, but it cannot replace professional judgement. Complex ownership structures, trusts, overseas entities or higher-risk customers often require specialist input. Agencies should understand what happens when staff encounter situations they're unsure how to manage.

The strongest approach combines purpose-built technology for everyday compliance with certified AML specialists for the situations software can't solve on its own.

Mistake 7: Thinking in parts instead of systems

Some agencies assume they can piece together compliance by using one system for customer onboarding, another for identity verification, another for training and another for policies and recordkeeping. Others assume their CRM already covers enough of the requirements.

The problem is that compliance isn't a collection of separate tasks – it's a connected system. Policies, risk assessments, customer verification, staff training, ongoing monitoring, reporting and recordkeeping all need to work together.

When information is spread across multiple systems, it's easier for tasks to be missed, records to become inconsistent and audit trails to break down. Staff may duplicate work, struggle to find the right information or rely on manual processes that increase the risk of errors. What looks like a lower-cost approach can quickly become more expensive through additional administration, operational inefficiencies and greater compliance risk. 

A single, integrated system gives agencies better visibility, stronger controls and greater confidence that nothing falls through the cracks.

Compliance doesn't have to slow your agency down

The agencies that get ahead of Tranche 2 won't necessarily be the ones spending the most on compliance. They'll be the ones that build practical systems that fit naturally into the way they already work. When compliance becomes part of the customer journey instead of a separate administrative task, it becomes much easier to keep deals moving.

About Visibl

Visibl is an Australian AML/CTF compliance platform built specifically for businesses captured under Australia's Tranche 2 reforms. Combining purpose-built technology with certified AML specialists, Visibl helps real estate agencies implement, manage and demonstrate AML/CTF compliance through digital onboarding, customer verification, risk assessments, monitoring, reporting, training and audit-ready recordkeeping, all in one platform that keeps deals on track.