Part 4: How to Prepare — A Practical Guide for Property Owners and Investors
Over the past three articles, we’ve explored what Australia’s upcoming Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms are, why they are being introduced, and what they mean for the commercial real estate sector.
Now we turn to the most important question:
What should you actually do about it?
With the reforms taking effect from 1 July 2026, the reality is that while much of the compliance burden will sit with agents and advisors, clients—particularly property owners and investors—will play a key role in how smoothly transactions proceed.
The good news is that preparation does not need to be complex. With a clear understanding of what is likely to be required, you can position yourself to transact efficiently and with minimal disruption.
A shift in mindset: from reactive to prepared
Historically, property transactions have often been relatively straightforward from a documentation perspective—particularly in domestic, arms-length deals.
Under the new AML/CTF regime, that mindset will need to shift.
Rather than responding to information requests as they arise, clients who are prepared upfront will be better placed to:
- Avoid delays
- Reduce friction in negotiations
- Present as credible and organised counterparties
In a more structured transaction environment, preparedness will become a competitive advantage.
What you are likely to be asked for
While exact requirements will vary depending on the nature of the transaction, there are several categories of information that are likely to become standard.
1. Identification documents
For individuals, this may include:
- Passport or driver’s licence
- Proof of address
For entities, this may extend to:
- Company registration details
- Director information
- Trust deeds (where applicable)
2. Ownership Structures
Where property is being bought or sold through a company or trust, there will be an increased focus on identifying beneficial ownership.
This means clearly outlining:
- Who ultimately owns or controls the entity
- How ownership is structured
- Any related parties involved
For more complex structures, having this information readily available will be critical.
3. Source Of Funds (Where Required)
In certain circumstances—particularly where transactions are considered higher risk—you may be asked to provide information about the origin of funds.
This could include:
- Bank statements
- Evidence of business income
- Sale proceeds from previous assets
It’s important to note that this will not apply to every transaction, but where it does, being able to respond quickly will help keep deals moving.
Where delays are most likely to occur
One of the most common concerns around AML/CTF reform is the potential for delays in transactions.
In practice, delays are most likely to arise where:
- Ownership structures are unclear or poorly documented
- Required information is not readily available
- There are inconsistencies in documentation
- Additional verification is required late in the process
In many cases, these delays can be avoided with early preparation.
Practical steps you can take now
While the reforms do not commence until 1 July 2026, there is value in preparing ahead of time—particularly if you are actively transacting or considering doing so in the next 12–24 months.
1. Review your ownership structures
If you hold property through companies, trusts, or other entities, take the time to ensure:
- Documentation is up to date
- Ownership is clearly defined
- Records are easily accessible
If your structures are complex, consider whether they are still fit for purpose in a more transparent regulatory environment.
2. Organise key documentation
Having core documents readily available can significantly reduce delays.
This may include:
- Identification documents
- Company extracts
- Trust deeds
- Historical transaction records
Think of this as creating a “transaction-ready” file.
3. Understand your funding position
If you are planning to acquire property, be prepared to clearly demonstrate:
- Where funds are coming from
- How the transaction will be financed
This does not mean over-preparing for every scenario, but having a clear and consistent explanation will be valuable.
4. Engage with informed advisors
Not all agents and advisors will be at the same stage of readiness when these reforms come into effect.
Working with professionals who:
- Understand AML/CTF requirements
- Have systems and processes in place
- Can guide you through compliance efficiently
…will make a meaningful difference to your transaction experience.
5. Allow For Additional Time In Transactions
As processes evolve, it is prudent to build some flexibility into transaction timelines—particularly for more complex deals.
This is less about expecting delays, and more about allowing for a more structured process.
What this means for vendors
If you are considering selling a commercial property, preparation will become increasingly important.
Well-prepared vendors who:
- Have clear ownership structures
- Can provide documentation quickly
- Work with organised agents
…are more likely to:
- Maintain momentum in campaigns
- Reduce friction during due diligence
- Provide confidence to prospective buyers
In a competitive market, this can have a direct impact on outcomes.
What this means for buyers and investors
For buyers, particularly those operating through entities or across multiple investments, the key will be clarity and consistency.
Being able to clearly demonstrate:
- Who you are
- How you operate
- Where your capital is coming from
…will position you as a low-risk, credible counterparty.
This can be particularly important in:
- Off-market transactions
- Competitive bidding environments
- Deals involving multiple stakeholders
The role of your agent is changing
As AML/CTF reforms take effect, the role of the commercial real estate agent will evolve.
In addition to facilitating transactions, agents will increasingly act as:
- Compliance gatekeepers
- Process managers
- Risk assessors
This makes the choice of agent more important than ever.
An agent who is prepared and structured will not only meet regulatory requirements but will also help ensure that transactions progress efficiently.
Turning compliance into confidence
It’s easy to view AML/CTF reform purely through the lens of compliance.
However, there is another way to look at it.
A more transparent, structured transaction environment can:
- Reduce uncertainty
- Improve the quality of counterparties
- Strengthen trust across the market
For investors and property owners, this can translate into greater confidence when making decisions.
A window of opportunity
Between now and 1 July 2026, there is a window of opportunity.
Those who take the time to understand the changes and prepare accordingly will be well positioned as the market adjusts.
Those who wait until the last minute may find themselves reacting to new requirements under time pressure.
Final thoughts
AML/CTF reform is coming—and with it, a shift in how commercial real estate transactions are conducted in Australia.
While the changes introduce new processes, they do not fundamentally alter the nature of the market. Deals will still be done, opportunities will still exist, and capital will continue to flow.
What will change is the level of structure, transparency, and preparation required to move those deals forward.
For property owners and investors, the message is simple:
Be prepared, be organised, and work with the right people.
Series wrap-up
Across this four-part series, we’ve covered:
- What AML/CTF reform is and why it is being introduced
- The industries captured under Tranche 2
- The specific impact on commercial real estate
- Practical steps to prepare for change
As the 2026 commencement date approaches, we will continue to monitor developments and provide guidance to help our clients navigate the evolving landscape.
References:
- AUSTRAC (2024), AML/CTF Reform Program Overview
- AUSTRAC (2024), Regulatory Expectations and Industry Guidance
- NSW Small Business Commission (2024), Preparing for AML/CTF Changes
- Financial Action Task Force (FATF), Risk-Based Approach Guidance