Foreign buyer using a local proxy: red flags for agents

People search “foreign buyer verification AML” when a suburban agency has a local contact running the negotiation for a buyer who will not complete the check. Checked against AUSTRAC’s real estate suspicious-activity indicators 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 is who is the customer in real estate AML. What a suspicious matter is for a new firm is suspicious matter reports in Tranche 2. The sector map is /tranche-2.

The person in the room may not be the buyer

Foreign interest in Australian property is ordinary, and a proxy is the problem when the person making the decisions is not the person your program calls the customer, and the named buyer will not be identified. AUSTRAC publishes risk indicators for the real estate sector. This page does not reproduce them. It sorts the pattern an agency actually sees: a local contact, an overseas name on the contract, and pressure to exchange before the check.

You do not coach anyone on how to stand in for a buyer, and you identify the customer, you apply the program, and you escalate inside the firm when the pattern worries you. Telling the contact that you might report them is the harm to avoid. What not to say to a client lives on the tipping-off page. This page only says: do not warn them.

• Name the customer first. The contract name is where you start. The person who attended the open home is not a substitute customer.
• Treat the offer to complete someone else’s check as a flag. A representative can pass messages. They cannot become the buyer on the result.
• Ask where the price is coming from. Funds from a person who will not be on title, and will not be explained, are a reason to re-read the program, not a reason to exchange faster.
• Escalate inside, not outward. The principal or the compliance officer hears the pattern. The buyer and the proxy do not hear that a report is being considered.

Patterns on a suburban listing

Sanctions screening is a separate screen, on sanctions screening in Australia. A foreign address is not itself a sanctions hit. What you must not tell the client is what not to tell a client about tipping off.

Where the proxy page stops

This page is the agent’s red flags when a local contact stands in for a buyer. It is not a guide to using a proxy, and it is not the suspicious-matter form. FreeAML does not decide that a pattern is suspicious and does not lodge a report.

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. A proxy does not pay in place of the customer’s own check, and the agency does not absorb the list price into commission. Confirm the live amounts on FreeAML pricing. FreeAML does not decide the buyer is genuine or tell the proxy you are considering a report.

Frequently Asked Questions