Do I still need a solicitor for AML/CTF Tranche 2 compliance?

Yes. HeadStart Docs products are digital publications that give you a substantial head start, but they must be reviewed and tailored by a qualified solicitor to your specific business circumstances before implementation.

How is HeadStart Docs different from the free AUSTRAC Starter Kits?

AUSTRAC Starter Kits are generic starting points that require significant customisation. HeadStart products are sector-specific, pre-populated with industry-relevant risk factors and scenarios, and include 12 months of AML Portal access for ongoing compliance including screening, record keeping and reporting tools.

What if the AML/CTF rules change after I purchase?

Your digital products are yours to keep. If significant regulatory changes occur, updated versions will be available to active portal subscribers. The AML Portal itself is continuously updated to reflect current AUSTRAC requirements and sanctions lists.

What happens after my 12-month AML portal access expires?

Your documentation is yours forever. To continue using the AML Portal (screening tools, compliance calendar, record keeping), you pay $35 per customer CDD. Cancel anytime — no subscription required.

Is HeadStart Docs a law firm?

No. HeadStart Docs is a digital publisher and platform provider. We sell digital compliance products and portal access. We do not provide legal advice. Referrals for legal advice can be made to our related law firm, HeadStart Counsel.

When does AML/CTF Tranche 2 commence in Australia?

Tranche 2 AML/CTF obligations commence on 1 July 2026. All reporting entities in designated sectors including lawyers, accountants, real estate agents, conveyancers, and trust and company service providers must have their AML/CTF programs in place by this date.

What AML/CTF documentation do buyer's agents need?

Buyer's Agents need an AML/CTF program including: Client Identity Verification, Beneficial Ownership Identification, Source of Funds Enquiries. Our digital products provide a headstart on compliance documentation.

When does Tranche 2 commence for buyer's agents?

Tranche 2 AML/CTF obligations for real estate sectors commence from 1 July 2026. AUSTRAC enrolment opens from 31 March 2026. Businesses should begin preparing their AML/CTF programs now.

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Buyer's Agents

Name: HeadStart Docs
Brand: HeadStart Docs
Price: 679 AUD

Buyers agents acting on behalf of purchasers in property transactions are in scope for Tranche 2. Here's what you need to know before 1 July 2026.

New to Tranche 2? Read our comprehensive guide

Who is captured under Tranche 2?

Likely captured

Buyer's agents and buyer's advocates providing property acquisition services are captured under Tranche 2. Includes residential purchases, commercial acquisitions and investment property sourcing. Seek legal advice to confirm your specific obligations.

Available Now: Real Estate Edition

Free program documents

A headstart on AML compliance. Program documents tailored to buyer's agents operations, from $249 one-time (or bring your own program). Your lawyer reviews and signs off before you go live.

A HeadStart on Compliance

Digital products to help you build your AML/CTF program, whether or not you are in scope

Ready-to-Customise Resources

Documentation tailored to your sector, ready to customise with your lawyer

Team Training

Staff training materials for your team and compliance officers

Key AML/CTF Areas for Buyer's Agents

Our documentation covers all critical AML/CTF compliance areas specific to your profession. Your lawyer reviews and tailors these to your business before you go live. We include a structured brief so the review is efficient.

Client Identity Verification
Customer due diligence for all buyer clients before engagement, including electronic verification methods.
Beneficial Ownership Identification
Requirements when clients are companies, trusts, SMSFs, or other structures purchasing property.
Source of Funds Enquiries
Procedures for verifying how clients will fund their property purchase.
Transaction Monitoring
Ongoing monitoring of client transactions and property acquisition patterns.
Third-Party Payment Protocols
Risk management for deposits and payments from parties not directly involved.
Suspicious Matter Reporting
Workflows for identifying and reporting suspicious matters to AUSTRAC.

What's Included in Your Real Estate Edition

Digital products tailored to buyer's agents operations, ready to customise with your lawyer.

• AML/CTF program framework for buyer's agents
• Risk assessment worksheet (ML/TF/PF risks)
• Client identification and verification procedures
• Beneficial ownership identification protocols
• Source of funds enquiry procedures
• Transaction monitoring workflows
• Suspicious matter reporting procedures
• Recordkeeping schedules and requirements
• Staff Training Register
• Compliance officer role description

Related Sectors:

Free Tools

Implementation TimelineKey dates and milestones for Tranche 2 compliance Readiness TestAssess your compliance readiness in 2 minutes Sanctions ScreeningSearch Australian sanctions lists and country risk

Related Resources

Related Real Estate Professions

Property Managers Commercial Real Estate Agents Rural & Agricultural Property Agents Property Auctioneers

Disclaimer: This information is general in nature and does not constitute legal advice. HeadStart Docs™ provides digital products only, not legal services. Always seek advice specific to your circumstances from a qualified legal professional before implementing any AML/CTF program. We do not guarantee the accuracy of this information.