In August 2023, Singapore's police force ran the biggest anti-money laundering raid in the country's history. Ten people were arrested. What they seized wasn't just cash. It was Rolls-Royces, gold bars, 56 Bearbrick collectible figurines, grand pianos, and, above all, real estate. By the time the dust settled, the total value of assets connected to the case had climbed to roughly S$3 billion, making it one of the largest money laundering cases anywhere in the world.¹

What followed shows how enforcement in cases like this typically unfolds.

Singapore's Council for Estate Agents didn't just chase the criminals. It went back through the property transactions and asked a much simpler question: did the professionals who handled these deals do their jobs properly? In several cases, the answer was no.

Two real estate agents were fined in July 2025 for failing to carry out basic customer due diligence on transactions connected to the case.² Four law firms were penalised. One paid $100,000, another $30,000, a third received a formal notice of an intended $70,000 penalty, and a fourth got a private reprimand. Five individual lawyers were referred to the Law Society of Singapore for possible disciplinary action, including the head of one firm's entire conveyancing department.³ Nine banks and financial institutions were fined a combined S$27.45 million on top of that.⁴

None of these professionals were accused of laundering money themselves. Their offence was simpler, and honestly a bit more relatable. They didn't ask enough questions. Or they didn't write down what they'd checked. Or they kept working with a client even after a red flag had already gone up. One law firm had actually filed a suspicious transaction report on a client, and then kept acting for them without properly documenting why it still considered that appropriate. That gap in the paperwork was enough on its own to trigger a penalty.³

This is the standard Tranche 2 is bringing to Australia. You don't need to be a criminal to face regulatory consequences. You need to look closely enough at the person standing in front of you, and document that you did.

Australia isn't dealing with a hypothetical. AUSTRAC's own analysis has documented a case that follows almost the same pattern, right here in Sydney.

A foreign national wanted to buy a luxury apartment in Sydney's eastern suburbs. He made an all-cash offer, well above the asking price, the kind most agents would be thrilled to receive. The funds came from multiple offshore accounts, each linked to different companies registered in tax havens. The agent didn't ask where the money came from. Why would they? The buyer just seemed extravagantly wealthy.

AUSTRAC later traced those funds to a global money laundering operation tied to drug trafficking. The property was seized under proceeds-of-crime laws.⁵

That transaction happened before real estate agents in Australia had any legal obligation to check anything. From 1 July 2026, that excuse disappears. AUSTRAC estimates that around $1 billion in criminal proceeds flows through Australian property every year, and property has become one of the most attractive laundering vehicles precisely because it's stable, it appreciates, and until now it came with almost no questions asked.

It isn't complicated, really. Criminals need to turn dirty money, proceeds from drug trafficking, scams, tax evasion, fraud, into something that looks legitimate. Property does three things a suitcase of cash can't:

The same logic applies to high value, portable goods, which is part of why jewellers and precious metals dealers get swept into these regimes too. Hong Kong's Customs and Excise Department, for example, now runs an entire registration regime for dealers in precious metals and stones specifically because gold and jewellery are so easy to use to move and store value quietly.⁶ Since that regime took effect, Hong Kong Customs has run a steady stream of enforcement actions against small jewellery and gold dealers who bought or sold goods worth more than HK$120,000 without registering, arresting company directors, not criminal masterminds, over paperwork failures.⁷

That's the pattern worth sitting with. The enforcement rarely lands on the criminal. It lands on the professional who helped, however unknowingly, and however small their business was.

Australia has actually been an outlier for two decades. Most FATF member countries, the UK, Canada, Hong Kong, Singapore, brought real estate agents, lawyers, conveyancers, accountants and precious metals dealers ("Tranche 2 entities") into their AML regimes years, sometimes decades, ago. Australia kept delaying, largely because of industry pushback over cost and complexity.

That delay came at a cost to Australia's international standing. The Financial Action Task Force had flagged the gap repeatedly, and it became one of the clearest weaknesses in Australia's AML framework on the global stage.⁸ The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 finally closed it, bringing roughly 73,000 additional businesses under AUSTRAC's supervision, including real estate agents, lawyers, conveyancers, accountants, trust and company service providers, and dealers in precious metals and stones, effective from 1 July 2026.⁹

If you run a small agency, a sole practitioner conveyancing firm, a boutique jewellery business or a one person accounting practice, you are now a "reporting entity" under the same Act that has fined Australia's biggest banks and casinos hundreds of millions of dollars. AUSTRAC has been explicit that size is no defence. The obligations apply regardless of the size of your business.¹⁰

You are not expected to become a financial crime investigator. But from 1 July 2026, if your business provides a "designated service" (brokering a property sale, handling conveyancing, selling jewellery over a certain threshold, structuring a trust), you will need to:

The penalties for getting this wrong aren't symbolic. Civil penalties for corporations can run into the tens of millions of dollars, and individuals can face criminal charges, imprisonment, and loss of their professional licence under state based dishonesty provisions. A real estate licence or legal practising certificate can be stripped following a relevant conviction.¹²

The Singapore case and the Sydney apartment case are really the same story told from two angles. In Singapore, the professionals didn't launder anything themselves. They just didn't ask hard enough questions, or didn't write the answers down. In Sydney, the agent simply assumed a generous cash buyer was a lucky windfall rather than a warning sign.

From 1 July 2026, "I didn't think to ask" stops being a viable answer in Australia too. The good news is that compliance, done properly, mostly comes down to habits: knowing your client, writing down what you find, and knowing when something doesn't sit right. The next article in this series covers exactly what those red flags look like in practice, the specific signs that should make you pause before you go ahead with a deal.

Next in this series: "Case Study: Common Red Flags in Real Estate and Legal Transactions", the practical signs that separate a routine transaction from one that carries compliance risk.