New anti-money laundering laws are coming for Queensland property transactions
Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime is expanding, and property transactions are now a key focus. From 1 July 2026, Tranche 2 reforms will extend these laws to professions involved in property dealings, including lawyers, conveyancers and real estate agents when they work in “designated services” including the buying and selling of real estate but at this stage most likely not leasing real estate for terms less than 30 years. While proper identification of the client was already necessary for lawyers at least (for example, taking copies of a passport and driver licence to establish identity for electronic conveyancing purposes), these professionals will now be required to carry out further client due diligence as part of everyday property transactions, bringing the process closer to what borrowers already experience with lenders. Buyers and sellers on the Gold Coast will still be able to transact as usual, but the processwill involve more upfront verification. A conveyancing lawyer will need to inspect more documentation, with closer scrutiny of how funds are sourced and used. Businesses involved in property transactions should note that the AUSTRAC enrolment window has already opened as of 31 March 2026. It is important to act now ahead of the 1 July 2026 compliance deadline. Why are property transactions being targeted? Property has long been identified as a potential channel for money laundering due to the high value of transactions and the ability to structure ownership in different ways. Extending AML/CTF obligations to property-related services is also part of Australia’s broader effort to align with international standards. The reforms aim to improve transparency across the Australian property market, which directly impacts clients working with property lawyers on the Gold Coast. On 1 July, 2026 an estimated 80,000 to 90,000 new reporting entities are expected to enter the AML/CTF regime nationally. What the new laws require Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, businesses providing “designated services” must meet a series of compliance obligations. From 1 July 2026, this will include property-related services in Queensland. The designated services include: Customer due diligence Professionals must verify the identity of clients and understand who they are dealing with. Additional checks may apply where a transaction is considered higher risk, such as where complex ownership structures are involved. This shifts the role of legal and property professionals from purely transactional to actively assessing risk. In practice, this will often include VOI requirements, where clients must provide identification documents and, in some cases, complete face-to-face or electronic identity verification processes before work can commence. Where the client is a company or acts as a trustee, the “owner” of the client has to be identified and their identity verified. This means that the constitution of the company may be examined together with any trust deeds, and the VOI is likely to be required on: A fairly typical structure would be a company either acting as a trustee for a discretionary trust, or having a shareholder that is a trustee for a discretionary trust. The VOI is likely to require: What is VOI and what does it involve? VOI is a key part of the due diligence process and will become a standard requirement in most property transactions. VOI can be completed in several ways. In some cases, it is carried out face-to-face, where original identification documents such as a passport or driver licence are sighted and verified. Electronic VOI is also commonly used through secure digital platforms. Clients may be asked to provide multiple forms of identification. Where there are discrepancies, further verification may be required before the transaction can proceed. VOI is typically required early in the transaction process. Delays in completing VOI can slow transactions, so having valid and up-to-date identification ready is important for buyers and sellers on the Gold Coast. Ongoing monitoring and reporting Transactions must be monitored for unusual or suspicious activity. If concerns arise, professionals are required to submit reports to AUSTRAC, including suspicious matter reports and threshold transaction reports for cash payments of $10,000 or more. The professional is not permitted to inform their client that the report has been made. This means transactions are not just checked at the start. They are assessed throughout the process. These reporting obligations are designed to support law enforcement and protect the integrity of the financial system, including transactions overseen by a Gold Coast lawyer. Record keeping and compliance programs Businesses must maintain detailed records of transactions and client information, generally for at least seven years. This applies across legal services, including those provided bycommercial lease solicitors and professionals involved in property conveyancing. How will due diligence obligations apply to lawyers? Legal professionals will now be required to carry out similar AML/CTF checks when providing designated services. This means lawyers must take active steps to identify their clients, understand the nature of the transaction and assess whether there is a risk of money laundering or other financial crime. In practice, this may include verifying identity, confirming the source of funds, and understanding the ownership structure behind a purchase. Lawyers must also monitor transactions for inconsistencies or unusual activity. How this will affect property transactions in Queensland The introduction of these laws will not prevent property transactions from proceeding, but it will change how they are managed.More documentation will be required throughout the process. Evidence showing the source of funds may be requested before a transaction can move forward. Transactions involving trusts, companies or international funds are likely to require additional review, which can extend the timeline compared to more straightforward purchases. Legal professionals and agents will take on a more active role in compliance. Disputes that arise in this context may involve a property litigation lawyer or lawyers for litigation. Property developers may also be captured under the Tranche 2 reforms where they provide designated services connected to property transactions. Legal professional privilege remains The reforms include safeguards for legal professional privilege. This is particularly relevant in Queensland property transactions where legal advice forms part of the