AML/CTF Designated Services Decision Trees | When Do You Need AML Checks?

Not every client interaction requires AML verification. "Designated services" are specific activities that trigger AML/CTF obligations. This guide helps you decide when verification is required.

Golden Rule

If in doubt, verify. Over-compliance is safer than non-compliance. Penalties for missing required checks can reach $27 million.

Real Estate: When to Verify

✅ VERIFY REQUIRED:

Property sales (buying or selling)
Lease agreements (tenant or landlord)
Property management agreements

❌ NO VERIFICATION NEEDED:

×Property appraisals (market valuations)
×Open home inspections
×General inquiries or consultations

Accountants & Tax Agents: When to Verify

✅ VERIFY REQUIRED:

Tax return preparation and lodgment
Financial advice or planning services
Trust or company formation services
Acting as trustee, director, or company secretary

❌ NO VERIFICATION NEEDED:

×Bookkeeping services only
×Payroll processing
×General business advice (no tax/financial component)

Lawyers & Conveyancers: When to Verify

✅ VERIFY REQUIRED:

Property settlements and conveyancing
Trust or estate management
Company formation or corporate services
Handling client funds in trust accounts

❌ NO VERIFICATION NEEDED:

×Employment law advice
×Criminal defense representation
×Intellectual property matters

Jewellers & High-Value Dealers: When to Verify

✅ VERIFY REQUIRED:

Any transaction over $10,000 (single or linked transactions)
Multiple transactions totaling $10,000+ within 7 days
Precious metals, stones, jewellery, watches, art, vehicles

❌ NO VERIFICATION NEEDED:

×Transactions under $10,000
×Repairs or maintenance services
×Appraisals or valuations only

Quick Decision Flowchart

1
Is this a designated service?
Check the lists above. If YES → continue. If NO → no verification needed.
2
Have you verified this client before?
If YES and it's within review period (12-36 months) → no re-verification needed. If NO or expired → verify now.
3
Is the client an individual or entity?
Individual → $15 KYC check. Entity → $35 KYB + $15 per beneficial owner.

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Designated Services Decision Trees: When Do You Need AML Checks?

Golden Rule

Real Estate: When to Verify

✅ VERIFY REQUIRED:

❌ NO VERIFICATION NEEDED:

Accountants & Tax Agents: When to Verify

✅ VERIFY REQUIRED:

❌ NO VERIFICATION NEEDED:

Lawyers & Conveyancers: When to Verify

✅ VERIFY REQUIRED:

❌ NO VERIFICATION NEEDED:

Jewellers & High-Value Dealers: When to Verify

✅ VERIFY REQUIRED:

❌ NO VERIFICATION NEEDED:

Quick Decision Flowchart

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