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Compliance
October 4, 20269 min read

Nomination of a substitute buyer before settlement

A nomination of a substitute buyer before settlement makes the nominee a new customer. The original purchaser's customer due diligence does not cover them.

Quick answer

Treat the nominee as a new customer of the transfer you are about to assist. Complete customer due diligence on that nominee before you assist their side of the settlement. If the nominee is a company, that is KYB, not a reused personal check. The original buyer's result stays on the original file, and it does not move.

People search “nomination new buyer AML” when a nomination deed arrives the week before settlement and the file already has a green result for the original buyer. Checked against AUSTRAC's overview of initial customer due diligence on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Customers you must know before the matter gets going are pre-commencement customer AML. The conveyancer's own service is AML for conveyancers assisting a transfer. The sector map is /tranche-2.

The green result does not travel

A nomination replaces, or adds, the person who will take the transfer. Your file can already show a completed check on the buyer who signed the contract. That result answers yesterday's customer, and the nominee was not that customer. Using it because settlement is close is how a substitute buyer arrives unidentified.

Do the work before you assist the nominee's settlement, not in a tidy-up the week after, and a person nominee is a KYC check. A company or a trust nominee is a KYB check, and then the individuals your program names behind it. Urgency from the agent is not a customer type. If your program allows a delay, that permission is a different page, and a nomination is a poor place to assume it applies.

  • Read the nominee's name as a new customer. Do not annotate the original check with 'and nominee'.
  • Match the check to the entity. A person is KYC. A company or trust is KYB. The deed's covering email does not choose.
  • Keep the original result where it is. It still records the first buyer. It does not identify the second.
  • Settle the order, not the panic. Assist the nominee after the check your program requires, not before it because Friday is busy.

What changes when the deed arrives

A sorting aid for a nomination before settlement. This table does not reproduce AUSTRAC's initial customer due diligence overview.

Who is taking the propertyWhat you doWhat you do not reuse
A different individualKYC on the nomineeThe original buyer's result
A company the original buyer controlsKYB on that companyA personal check on the first buyer, relabelled
A trustKYB on the trust, then the people the program namesThe trustee's driver's licence alone
The original buyer, deed withdrawnNo new customer from the deedA second check you opened in a hurry

Where the nomination page stops

This page is the substitute buyer. It is not the general pre-commencement timing, and it is not the whole of a conveyancer's designated service. Those are pre-commencement customer AML and AML for conveyancers assisting a transfer.

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. The nominee is not included in the original buyer's check, so their verification is its own client-pays check. Confirm the live amounts on FreeAML pricing. FreeAML does not treat the nominee as already identified or decide the nomination is out of scope.

Frequently Asked Questions

New buyer, new link, before settlement.

The firm suite is A$0. The client pays. The firm emails the nominee a link. KYC is A$20 for a person. KYB is A$40 if the nominee is a company or a trust.

Start a KYC check

Questions: team@freeaml.com.au