Mortgage broker AML: different regime, do not blend the advice

People search “mortgage broker tranche 2” when a mortgage broker is handed a real estate AML pack and told it is the same regime. Checked against AUSTRAC’s real estate designated services page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The agency path is real estate AML compliance. Who the customer is on an agency file is who the customer is in real estate. The sector map is /tranche-2.

Two businesses, two programs

Mortgage broker Tranche 2 is a confusing phrase because the broker and the selling agent can stand in the same kitchen. They are not providing the same service. The agent’s Tranche 2 question is about real estate designated services. The broker’s question is about the credit regime that already applied to broking; using one pack for both produces a program that describes neither office.

This page will not restate the broker’s existing duties, and it will not copy the real estate designated services. AUSTRAC’s real estate page is the official source for the agency side. This article does not reproduce it. If one human holds both licences, they still write two analyses; the buyer’s-agent page on this site is about agents, not about credit brokers; do not send a broker there for their program.

• Match the pack to the licence. An agency starter kit is for the agency. It is not a broker policy with the logo swapped.
• Do not inherit the other party’s customer. The broker’s client and the agent’s customer can be the same human and still two files.
• Do not share a shortcut. The agent is not covered because the broker did a check, and the broker is not covered because the agent enrolled.
• Split a dual business. Two services, two writes. One Word file that says both is how the regimes get blended.

Kitchen-table confusion

Where this page stops

This page is the warning not to blend. It is not the agency customer page. That page is who does CDD in a real estate agency.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. A blended broker-and-agency program is not included, and the firm suite does not rewrite either regime. Confirm the live amounts on FreeAML pricing. FreeAML does not apply a real estate program to a mortgage broker or the reverse.

Frequently Asked Questions