Buyer's agent AML: your client is the buyer — read the item again
For a buyer’s agent, the client on the engagement is the buyer. Read the designated service again before you build a file on the seller.
Quick answer
The person who signed your buyer’s agency agreement is the customer you test against the item. The seller may be someone else’s customer, on someone else’s designated service. Do not copy a listing agency’s seller pack because a forum said both sides get identified. Write who you act for; then do that customer’s check; the firm emails the link; the client pays.
People search “AML for buyers agents” when a buyer’s agent has been told to verify the seller and has not re-read who the agreement names. Checked against AUSTRAC’s real estate designated services on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Whether you also verify a seller is a different article, buyer’s agents and seller verification. Who the customer is more broadly is on who is the customer in real estate. The sector map is /tranche-2.
Read the engagement, then the item
A buyer’s agent is paid by the buyer to find and secure a property. That engagement is the clue to the customer. The designated service item still has to be read, because a label on a business card is not the test. If the item covers brokering for the person you act for, the customer due diligence follows that person.
Listing agents talk about vendors because their agreement is with the vendor. Conveyancers talk about the party they are transferring for. Neither script is yours. If you collect a seller’s identity “because everyone does,” you may be doing someone else’s job, or no one’s job, without a program line that says the seller is your customer; this page does not redraft the item.
- Open the agreement. The name on the buyer’s agency agreement is the starting customer. A spouse who did not sign is a question, not an assumption.
- Re-read the item once. Match its verbs to what you were engaged to do. Do not match them to the seller’s agent’s job.
- Leave the seller’s pack with the seller’s firm. Their designated service is their program. Your copy of their form is not your CDD.
- Company buyer, different check. If your client is a company or a trust, the check is KYB, then the individuals your program names.
Who is in the buyer’s file
Write four names on the matter cover before you email anyone. Most of the confusion is a name in the wrong column. The column decides the link you send, and whether you send one at all.
A cover-sheet sort for a buyer’s agent. This table does not reproduce AUSTRAC’s real estate designated services.
| Person | Usually | The mix-up |
|---|---|---|
| Buyer who signed your agreement | Your customer | Treating them as “already done” by the selling agent |
| Seller | Another firm’s customer, unless your item and program say otherwise | Collecting their identity because a listing kit said to |
| Seller’s agent | Not the buyer | Accepting their word as your customer due diligence |
| Buyer’s company | A KYB customer if the company is the client | Checking only the person who came to the inspection |
Where the buyer’s-agent page stops
This page is who your client is. It is not the seller-verification debate and it is not the general “who is the customer” guide. Those are buyer’s agents and seller verification and who is the customer in real estate. FreeAML does not read your agreement.
The firm suite is A$0. When the program says the buyer must be verified, the firm emails that client a link and the client pays.
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. The firm suite does not include a check on a person who is not your customer, and it does not decide the item for you. Confirm the live amounts on FreeAML pricing. FreeAML does not decide who your customer is or whether the seller is in your scope.
📚 Related Resources
Real Estate AML Toolkit →
Complete compliance toolkit for property agents.
Real Estate AML Guide →
Everything agents need to know about Tranche 2.
Free KYC Check →
Verify customer identity in 60 seconds. Government ID + AML screening.
Free AML Program →
Board-ready AML/CTF Program template. All 10 AUSTRAC sections included.
Risk Assessment Generator →
AI-powered ML/TF risk assessment. 20-page compliant report in 5 minutes.
Free AML Training →
Online courses for staff. CPD-certified certificates included.
Frequently Asked Questions
Email the link to your client, the buyer.
The firm suite is A$0. The client pays. Use KYC for the person and KYB if the buyer is a company or a trust.
Start an AML checkQuestions: team@freeaml.com.au