Auction day: CDD before the hammer or before settlement?

People search “auction AML CDD timing” when a suburban agency is about to open bidding and has not written which moment is the designated service. Checked against AUSTRAC’s delayed initial customer due diligence page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The delay rules themselves are on delayed initial CDD. Who at the agency does the check is on who does CDD for real estate agents. The sector map is /tranche-2.

Two moments, one deadline

A suburban agency can have a crowd, a board, and a contract on the same Saturday. None of those is the AML clock. The clock is the point at which the agency provides the designated service named in its program. Staff need that point in writing before they print bidder numbers.

A verbal habit of “we always do identity at settlement” is not a program. Delay is a narrow permission, not an auction custom. If the program, matching the rules AUSTRAC explains for delayed initial due diligence, allows a delay, you finish as soon as practicable and you still know who you are dealing with. If it does not, you do not invent a delay because the bidder arrived late; this page does not decide which of your services are designated.

• Name the service first. Brokering a sale and assisting a later transfer are different jobs. The program says which one this agency provides.
• Put the moment on the file. Campaign open, hammer, exchange, or settlement. One line, dated, so Saturday staff are not guessing.
• Do not use the crowd as a reason. A full room is not a circumstance that postpones customer due diligence.
• Keep the underbidder separate. A person who registered and did not buy may still be your customer if the program says the service was the auction itself.

What Saturday staff can sort

The principal writes the rule mid-week. On the day, the auctioneer does not reinterpret it between lots. If identity is due before bidding, a bidder without a completed check does not get a number. If identity is due before settlement, the hammer can fall and the file still cannot settle until the check is done.

Where the auction page stops

This page is the timing choice for an agency auction. It is not the delay article and it is not a bidder script. How delay works is on delayed initial CDD. Which person at the agency collects the check is on who does CDD for real estate agents.

FreeAML does not run the auction and does not tell you the hammer is safe. When the program says a person or a company must be verified, the firm emails a link. 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. Deciding whether Saturday or settlement week is the deadline is program work, and it is not included in the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not decide whether the hammer or settlement is your designated service.

Frequently Asked Questions