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ARTICLE · 19 JUNE 2026

AML/CTF Countdown: Does The Travel Rule Apply To Property Developers?

Holding Redlich
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From 1 July 2026, Australia's Anti-Money Laundering and Counter-Terrorism Financing reforms will bring parts of the real estate sector into sharper regulatory focus. For property developers, one question is already emerging – could the 'travel rule' apply to how project funds, deposits or digital value move through a transaction? This article examines when the travel rule applies to property developers and what practical steps may be required.

AustraliaCorporate/Commercial Law
David Chambers
David Chambers
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From 1 July 2026, Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms will bring parts of the real estate sector into sharper regulatory focus. For property developers, one question is already emerging – could the ‘travel rule’ apply to how project funds, deposits or digital value move through a transaction?

The travel rule is best understood as a transparency obligation for transfers of value. It focuses on how value moves around a transaction, especially where funds or digital value are routed through arrangements that begin to resemble payment facilitation.

In practice, most property developers will not be directly subject to the travel rule simply because they sell real estate and receive purchase money. In a standard sale, the movement of funds is usually handled by banks, payment providers, lawyers, conveyancers, escrow agents or settlement platforms, rather than by the developer itself.

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This publication does not deal with every important topic or change in law and is not intended to be relied upon as a substitute for legal or other advice that may be relevant to the reader's specific circumstances. If you have found this publication of interest and would like to know more or wish to obtain legal advice relevant to your circumstances please contact one of the named individuals listed.

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