Developer internal sales team versus external agency

People search “developer in house sales AML” when a project marketer assumes the agency’s process has enrolled the developer, or the reverse. Checked against AUSTRAC’s real estate examples on dealing with customers on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Who does the check inside an agency is who does CDD for a real estate agent. Who the customer is on a sale is who is the customer in real estate AML. The sector map is /tranche-2.

Two businesses, one display suite

A display suite often has the developer’s people and an agency’s people in the same room, and the hoarding carries both names. AUSTRAC does not enrol a hoarding, and the developer in house sales AML question is whether the developer, through its own staff, is providing a real estate designated service. The agency’s question is whether the agency is providing one, and both can be yes. One being yes does not make the other no.

This page does not decide a project for you, and a suburban land estate and a city apartment release can be staffed differently. Read the contracts: who is appointed to sell, who takes the buyer’s offer, and who is paid. Then read AUSTRAC’s real estate material against those facts. Record the answer in each business, not in a shared slide.

• Payroll is a clue, not the test. Staff employed by the developer point at the developer. Commission paid to a licensed agency points at the agency. The designated service is still the test.
• Do not trade enrolments. The agency’s enrolment does not cover the developer. The developer’s enrolment does not cover the agency.
• The buyer is the customer of the business providing the service. Which business that is comes first. The customer page is the next question, not a substitute.
• Write it before the first exchange. A program written after a year of releases is how the display suite had no rule on Saturday.

Who asks the question

The sector map for agencies is real estate AML compliance. This page stays with the developer-versus-agency split.

Where the display-suite page stops

This page is who provides the service when a developer and an agency share a project. It is not the buyer’s identity check and it is not a franchise note. FreeAML does not enrol either business.

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. One project does not share one check across two businesses, and each business that must verify a customer has its own client-pays check. Confirm the live amounts on FreeAML pricing. FreeAML does not decide which entity provides the designated service on a project.

Frequently Asked Questions