What Tranche 2 means for the value of your real estate agency
From 1 July 2026, Tranche 2 of Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act will change, bringing real estate agents and some other businesses under the same compliance requirements as banks and financial institutions. If you operate a real estate agency in Australia, the way you respond to Tranche 2 reforms may affect its value.
It’s essential to understand the changes and update your policies and procedures accordingly, particularly if you plan to sell in the near future.
What is the Tranche 2 update, and why does it matter to real estate agencies?
Firstly, a ‘tranche’ is a portion of something. In this context, it refers to part of Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act.
AML/CTF regulations require certain businesses to take steps to prevent money laundering and terrorism financing. Key obligations for these reporting entities include:
Enrolling with Australia’s AML/CTF regulator AUSTRAC
Developing an AML/CTF program
Conducting customer due diligence
Reporting suspicious matters and certain transactions
Keeping the right records
These regulations have previously applied to banks, digital currency (crypto) exchanges and legal firms, but 2026 updates to Tranche 2 will expand the reach to designated non-financial businesses and professions, including real estate agents, buyers’ agents and property developers.
Being included in Tranche 2 means you’ll need to comply with the same obligations as banks and lawyers. To understand exactly what you need to do, take a look at this PDF or visit the AUSTRAC website.
You do have some time up your sleeve to ensure your agency is compliant, but if you’re thinking of selling in 2026, it’s worth being prepared ahead of time.
A new lens on valuation
Historically, real estate agency valuations have centred on earnings, rent rolls and sales goodwill. With Tranche 2 coming into effect, compliance maturity will also impact value.
Here’s how Tranche 2 will shape agency valuation:
1. Compliance-readiness will affect risk profiling
Buyers and investors will now look at whether an agency has the right systems, training and reporting protocols in place to comply with Tranche 2. A well-documented AML/CTF program will signal operational maturity and lower perceived regulatory risk.
2. Operational resilience will count
Once Tranche 2 comes into effect, responding to AML/CTF will be an ongoing business process embedded into day-to-day operations. If your agency has documented risk assessments, staff training protocols, clear identity checking processes and board-level oversight, and everything flows without affecting operations, it will be in a stronger position to demonstrate resilience and value.
3. KPIS and culture will form part of the valuation conversation
Your team is busy, but compliance awareness and activities should be included in their KPIs. They need to be well-informed, on board with the importance of compliance and supported enough to ensure the right boxes are ticked without becoming overwhelmed or burnt out. This will set you up for an easier sale.
What buyers and valuers will be looking for
Your agency has the potential to leverage the Tranche 2 update to improve its value. Valuers and buyers will be interested in seeing:
A fit-for-purpose AML/CTF program, aligned with AUSTRAC expectations
Documented risk assessments which reflect your client base and service model
Staff training logs and audit trails
Reporting records, including any Suspicious Matter Reports (SMRs) filed
Evidence of a culture of accountability
Seven years’ worth of records (or records from the period you have been in business)
If you’re looking to attract a premium on exit or expand your network through mergers or acquisitions, you’ll understand the value of putting these elements in place.
What to do now
Official obligations will apply from mid-2026, and AUSTRAC will publish final guidance in December 2025, but it’s never too early to prepare. The lead-up period is an ideal time to assess your exposure to risk, review your practices and policies, build internal capacity and ensure your processes are documented correctly.
If you’re unsure about where to start, a gap analysis can identify compliance blind spots (there are plenty of checklists and consultants available to help). From there, start developing your AML/CTF program, training your team and embedding the systems to support due diligence and ongoing monitoring.
Yes, it will be another administrative challenge for your business, but Tranche 2 has the potential to contribute positively to your value if you approach it as a lever for risk reduction and operational excellence.