Property developers selling off-the-plan: are you the reporting entity?

People search “AML for property developers” when a developer with an in-house sales suite asks whether the external agency, or the developer, is the reporting entity on off-the-plan stock. 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. Who the customer is on a sale sits on who is the customer for real estate AML. The conveyancer's separate duty is AML for conveyancers assisting a transfer. The sector map is /tranche-2.

In-house sales, or an independent agency

Developers assume the agency is always the reporting entity, because the agency has the licence and the listing. That is true when an independent agent brokers the sale. It is not the assumption when the developer sells its own off-the-plan stock through its own sales or marketing staff and no independent agent stands in the middle. In that shape, the developer is providing the selling service, and the customer is the buyer.

Read the appointment before you pick a side, and an external agency engaged to broker is the agency's designated-service question. An in-house suite with the developer's employees is the developer's. A conveyancer or lawyer assisting the transfer can be a reporting entity as well, on their own service. One project can involve more than one reporting entity, and this page will not rule on a particular site.

• Ignore the letterhead. Developer, builder, or marketing suite does not decide it. The selling service does.
• In-house means look at yourselves. Off-the-plan apartments sold by your own staff, without an independent agent, are the case to take seriously.
• An independent agency means look at them first. Brokering by an outside agency is that agency's service. Do not enrol 'just in case' and stop thinking.
• The conveyancer is extra, not instead. Their duty on the transfer does not wipe yours, and yours does not wipe theirs.

Four ways an off-the-plan campaign is staffed

Where the developer page stops

This page is whether a developer selling off the plan is the reporting entity. It is not the definition of the customer, and it is not the conveyancer's duty. Those are who is the customer for real estate AML and AML for conveyancers assisting a transfer.

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. Being the reporting entity is not a platform fee, and each buyer the program requires you to verify is a client-pays check. Confirm the live amounts on FreeAML pricing. FreeAML does not decide whether your development is a designated service or enrol the project.

Frequently Asked Questions