Like the real estate sales industry, rent roll transactions are entering a new era of scrutiny thanks to updated Anti-Money Laundering and Counter-Terrorism Financing laws.
As of 1 July 2026, anyone brokering the sale of a rent roll (or an agency) must comply with the new AML/CTF requirements by completing extra due diligence steps. If you’re buying or selling a rent roll, this means an additional layer of checks sits alongside the usual valuation, financing and settlement process.
AML/CTF explained
AML/CTF regulations introduced in July 2026 require businesses in some industries to take steps to prevent money laundering and terrorism financing. Obligations 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 previously applied to banks, digital currency (crypto) exchanges and legal firms, but the reach is now expanded to include real estate agents, buyers’ agents and property developers.
Why AML laws apply to rent roll transactions
Property-related services are treated as higher risk under the AML/CTF regime because they involve large sums and, at times, complex ownership structures.
Rent roll sales are included in the new regulations because they involve significant transaction values, business structures which may include trusts or companies, and multiple parties involved in funding the deal. This means extra steps for all stakeholders.
What to expect when you buy or sell a rent roll
As part of a rent roll sale, your broker is required to verify the identities of the purchaser and the vendor and to assess the money-laundering and terrorism-financing risk each party presents. This sits alongside the existing due diligence process, which covers management rights, staff stability, owner retention and financial performance.
You can expect:
Requests for identity documents for individuals, or beneficial ownership information for companies and trusts
Screening for politically exposed person (PEP) status
The assessment of risk factors such as unfinanced purchases, use of legal structures or third-party representatives
To be asked for proof of where funds are coming from (if you’re the buyer)
Any suspicious matters to be reported to AUSTRAC
For vendors, this due diligence must be completed before services are provided.
For purchasers, it must be finalised within fifteen days of contracts being signed, or before settlement, whichever comes first.
What to have ready
Expect to provide identification, prove the source of your purchasing funds, and answer questions about the structure behind your purchase.
If you’re a buyer acting through a company, trust or representative, additional information will be requested to confirm beneficial ownership and the authority to act.
A transaction which appears straightforward on paper but involves a foreign buyer, an unfinanced purchase or a representative acting on behalf of others may trigger a higher risk rating and a more detailed review as part of the due diligence process.
Agency owners preparing for sale should be ready to supply clear documentation on ownership and funding structures early, rather than leaving this until settlement approaches.
How BDH Solutions helps
Every rent roll transaction now carries an AML/CTF compliance step, regardless of the size of the deal or who is involved.
BDH Solutions incorporates these obligations into every transaction we oversee, working alongside our clients' loan brokers and legal advisers to keep the process moving efficiently. If you are considering a sale or an acquisition, speak with our team about how the new requirements apply to your transaction.
-
From 1 July 2026, anyone brokering the sale of a rent roll or agency must comply with expanded Anti-Money Laundering and Counter-Terrorism Financing laws. Obligations include enrolling with AUSTRAC, developing an AML/CTF program, conducting customer due diligence, reporting suspicious matters, and keeping accurate records that sit alongside the usual valuation, financing and settlement process.
-
Brokers must verify the identities of both parties and assess the money-laundering and terrorism-financing risk each presents. Expect requests for identity documents, beneficial ownership information for companies or trusts, screening for politically exposed person (PEP) status, and, for buyers, proof of the source of purchasing funds. Due diligence must be completed before services are provided to vendors, and within fifteen days of contracts being signed (or before settlement) for purchasers.
-
Prepare identification, evidence of the source of funds, and clear documentation on the ownership and funding structure behind the purchase, including beneficial ownership details if you're acting through a company, trust or representative. Foreign buyers, unfinanced purchases or third-party representatives may trigger a higher risk rating and a more detailed review, so having documentation ready early avoids delays at settlement.