Can you charge the client for an AML check in Australia?

Search results for “AML” often mix this topic with acute myeloid leukaemia. This page is about anti-money laundering checks for Australian firms: real estate, conveyancing, law, and accounting.

The obligation and the invoice are different

AUSTRAC’s overview of initial customer due diligence says a reporting entity completes initial CDD before it starts providing a designated service, except where a delayed-CDD rule applies. On reasonable grounds, the firm establishes the customer’s identity, anyone the service is really for, anyone acting for the customer and their authority, beneficial owners when the customer is not an individual, whether relevant people are politically exposed or designated for targeted financial sanctions, and the nature and purpose of the relationship. Some higher-risk matters also need source of funds and source of wealth. The firm keeps a record of how it established each point.

That work has a cost. Data sources, staff time, and the written program are real. Passing a disclosed amount to the client does not move the legal duty onto the client, and it does not turn your tax invoice into an AUSTRAC assessment. The sector overview of who is in scope is on /tranche-2.

Why this question is loud in 2026

Property forums have been asking a practical version of the same question since the reforms: can the agency put the verification on the vendor or the buyer? A typical thread is this AusPropertyChat discussion. Treat it as evidence of the commercial worry, not as a ruling. Industry explainers, including Forms Live on CDD and verification of identity, make the same split: identity work the market already knew, and a broader CDD file the firm must be able to show.

Cost write-ups from vendors are useful for the shape of the bill and risky as a price list. AML Guard’s pricing article separates verification cost from the operating cost of the program, and it describes their own customer-pays credit against a subscription. Visibl’s Tranche 2 cost note is another public discussion of what firms are budgeting. Confirm any dollar figure on the vendor’s own page before you repeat it to a client. ClearAML’s pricing page is the right place for ClearAML’s current plans.

Fee disclosure and disbursement norms

There is no single national “AML fee” you can paste onto every file. What travels well is ordinary professional practice: say what the charge is, say who pays it, and say it before the client is committed. State agency-agreement rules, legal costs disclosure, and engagement-letter practice differ. Your association or adviser is the authority for the form of words in your jurisdiction.

Call the line customer due diligence for your AML/CTF program, or a disclosed disbursement. “AUSTRAC fee”, “government levy”, and “compulsory AML tax” are labels that start arguments, because the client can read AUSTRAC’s site and see that the duty is yours. A line-item breakdown aimed at estate agents is in AML fees for estate agents.

Three ways the money can move

1. The firm absorbs it. The check is a cost of the matter. Simple, and it gets expensive when companies, trusts, and beneficial owners stack up.
2. The client pays the verification directly. On FreeAML, client-pays means the client’s card covers the verification and the firm’s cash for that check can be zero. The firm suite stays at A$0. Current verification pricing is on /pricing.
3. The firm charges its own disclosed fee and pays the vendor. The invoice can include a professional handling amount as well as the disbursement. Publish the split. There is no honest “standard industry AML fee” to hide behind.

Wording that survives a complaint

• Name the person or entity who was checked.
• Say the work is customer due diligence under your AML/CTF program.
• Separate a vendor disbursement from your professional fee when they differ.
• Say whether the client pays FreeAML directly or pays you.
• Keep the outcome, the risk note, and the invoice reference on the file.

A short client explanation, including how to talk about the check without scaring people off, is in how to talk about AML with clients. Send the request by email. FreeAML invites are email, so the client has a written trail of what they were asked to do.

When two firms touch the same file

An agent, a buyer’s agent, and a conveyancer can each decide they have a customer. If each runs a full check in silence, the client sees three lines and assumes someone is padding the bill. Agree who initiates customer due diligence, and tell the client. Another firm’s identity screenshot is not automatically your CDD record. AUSTRAC has a separate reliance framework; read it on the initial CDD overview and follow your program. The identity-versus-CDD distinction is is AML just VOI?.

What to read before you set a fee

• AUSTRAC: initial customer due diligence
• Forms Live: CDD and verification of identity for property
• FreeAML pricing for the current client-pays verification amounts
• What a free AML tool should include if the real argument is the software seat, not the disbursement

Frequently Asked Questions