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5 October 20269 min read

A CRM is not an AML check because it stores the listing

A real estate CRM such as REX, Agentbox or VaultRE stores the listing and the parties. That storage is not an AML check. Whether a particular CRM also runs identity verification is a claim on that vendor's current documentation. It is not established by the fact the agency already pays for the CRM.

Quick answer

Leave the listing in the CRM. Run customer due diligence as its own step, and file the result back on the listing. Do not assume the CRM vendor has built that step because the agency forum hopes they have.

Agencies ask whether REX, Agentbox or VaultRE β€œhandle AML” because the staff already live in one of those systems and a second screen feels like a new job. Checked against AUSTRAC's real estate designated services on 5 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Software aimed at agencies is discussed in AML software for real estate. Who you must know is who the customer is in real estate. What the check itself contains is what an AML check covers. The sector map is /tranche-2.

The CRM already has a job

A CRM keeps the appraisal, the listing, the opens, the offers and the names. That is the agency's operations. Brokering the sale, purchase or transfer of real estate, in the course of a business, is a designated service under table 5. AUSTRAC says the customers are both the seller or transferor and the buyer or transferee. For a seller's agent, the service to the seller starts when the agreement to broker is signed, and the service to the buyer starts when it is reasonably expected the transaction will proceed, typically when the offer is accepted and the contract is signed. A contact record created at the appraisal is not that legal sequence, and it is not customer due diligence.

This page does not audit REX, Agentbox or VaultRE, and it does not claim they lack an identity feature. Products add screens. A screen that collects a driver's licence photo into the listing is not automatically a reliable independent verification, and a screen that says β€œAML” on a tab might be a checklist with no check behind it. On the day you rely on it, open the vendor's own help page and run one seller and one buyer through it. If the result you can export does not establish the matters in your program, you still have the customer work to do. Hope is not a connector.

A pattern that does not wait on a roadmap

  • Seller, when the agency agreement is signed. That is when AUSTRAC says a seller's agent starts the designated service to the seller. Do not leave identity until exchange if your program requires it first.
  • Buyer, when the deal is real. Typically acceptance and contract, on AUSTRAC's description. An enquiry at an open home is not yet that moment. Your program can still be stricter.
  • Both parties. One CRM card does not cover the other side.
  • Company or trust as purchaser. That is KYB, then the people the program names. A contact name is not the beneficial owner.
  • File the result on the listing. The CRM is the cabinet. The check is the document you put in it.

CRM against customer due diligence. This table does not review a named product.

NeedCRMCheck
Remember the propertyYesNo
Know both parties before the service proceedsOnly if you use it as the fileThe verification the program requires
A company buyerA name on a cardKYB, not a nickname in the CRM
Show AUSTRAC the record laterIf you saved the result thereA tab with no result behind it

Auction day is not a reason to pretend the CRM checked anyone

AUSTRAC says that at auction the buyer may be known only after the fall of the hammer, and that initial customer due diligence can be delayed where doing it immediately would disrupt the ordinary course of business. That delay is about timing. It is not a finding that the CRM's bidder number was the check. Read the delayed-verification guidance before you use it, and complete the work your program requires as soon as you reasonably can. A bidder paddle is not a KYC result.

FreeAML sits beside the CRM. The firm emails the client a link. The client pays. You save the PDF on the listing in REX, Agentbox, VaultRE, or whatever you use. No integration claim is made here, because a claim of that sort has to be true of a named build on a named day. The legal job does not wait for the vendor's next release.

Where this page stops

This page is the CRM. It is not every real estate service, including a developer selling without an agent, which is in-house developer sales.

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. There is no subscription. Confirm the live amounts on FreeAML pricing. FreeAML does not bill a CRM seat. The identity check is client-pays. The agency's listing software remains the agency's contract.

Frequently Asked Questions

Keep the CRM. Email the check link beside it.

The firm suite is A$0. The client pays A$20 for KYC or A$40 for KYB. The listing software does not have to be the check.

Start a KYC check

Questions: team@freeaml.com.au