Giftor on a property purchase: do you CDD the person giving the deposit?
You do not automatically run full customer due diligence on every giftor. You identify the buyer, and you treat the gift as a risk fact the program knows how to weigh.
Quick answer
Giftor verification on a property file starts with the buyer named on the contract, and a parent paying a deposit is often a third party providing funds, not a second customer. You record who is giving, whether it is a gift or a loan, and whether the pattern looks like the giftor is the real purchaser. Full CDD on the giftor is what the program requires when the risk says so, or when that person is the true customer, and the firm emails a link for the check that is actually required. The client pays.
People search “giftor verification property AML” when a conveyancer on settlement is told the deposit came from a parent and is unsure whether that parent is now a customer. Checked against the conveyancer starter kit getting-started page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Who the customer is, before any gift, is who is the customer in real estate AML. When extra measures apply is enhanced customer due diligence in Australia. The sector map is /tranche-2.
Donor, buyer, or both
A deposit from parents is common on an Australian purchase, and the conveyancer’s first customer is the buyer on the contract, identified the way the program says. The giftor is the person providing funds. Those are different roles, and they collapse only when the giftor is in substance the purchaser using another name. Giftor verification property AML is the decision between those two pictures, not a rule that every birthday transfer becomes a second file.
You ask enough to know which picture you have, and who is giving, is it a gift or a loan, does the amount match the story, and does the giftor appear to be making the decisions. AUSTRAC’s conveyancer kit is the sector starting point you customise. This page does not reproduce it and does not set a dollar figure at which a gift becomes enhanced due diligence. The program sets that.
- Start with the buyer. The name on the contract is the customer you identify first. The deposit slip does not replace that name.
- Record the gift as a fact. Who gave it, gift or loan, and whether it fits the file. A blank is not the same as a low-risk decision.
- Move to CDD on the giftor when the program says so. That is a risk decision or a true-customer decision. It is not a courtesy check on every parent.
- If the giftor is the real buyer, restart. The customer question changes. Do not keep the child as a paper customer to avoid the parent’s check.
Deposit stories on settlement
A conveyancer’s role when assisting a transfer is AML for conveyancers assisting a transfer. The giftor point stays on this page.
A sorting aid for a conveyancer. This table does not reproduce the conveyancer starter kit.
| Story | Usual role of the payer | When the role changes |
|---|---|---|
| Parent gifts a deposit, buyer is the adult child on the contract | Source of funds | You identify the giftor as a customer only if the program’s risk rule says so |
| The giftor negotiates, chooses the property, and will live there | Looks like the true buyer | The customer question is reopened |
| A private lender, described as a gift | Not a gift | Treat the loan fact honestly and re-read the program |
| Stranger provides the price and will not be explained | Unexplained third party | This is not a family gift, and the proxy question is a different page |
Where the giftor page stops
This page is whether the person giving the deposit is a customer. It is not a source-of-funds form and it is not a rule for every third-party payer. FreeAML does not decide that a parent must be verified.
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 note that a parent provided the deposit is not itself a KYC fee, and a check on the giftor happens only when the program requires that person to be verified. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that the giftor is a customer or clear the gift.
📚 Related Resources
Lawyer AML Toolkit →
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Frequently Asked Questions
Verify the person the program names.
The firm suite is A$0. The client pays. A personal KYC check is A$20. A company or trust KYB check is A$40.
Start a KYC checkQuestions: team@freeaml.com.au