ML/TF/PF business risk questions for an agency

People search “real estate ML TF risk questions” when a suburban principal starts the risk assessment with a generic city-agency template and no line for proliferation financing. 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 for real estate AML. The agency program as a whole is real estate AML compliance. The sector map is /tranche-2.

Three risks, one suburban book

Money laundering is the risk agents already talk about, usually as a cash buyer. Terrorism financing and proliferation financing are the lines a template drops because they feel remote from a Saturday open home. The assessment still asks them. An honest answer can be that the agency has not seen them, and that the agency knows what would make it look again.

Keep the questions on this shopfront. A beach suburb with holiday apartments is not an outer-suburban house book. Cash, third-party payers, company buyers, and pressure to exchange before you know who is buying are the patterns to count. Who may refuse to exchange is the control, and if only the vendor's urgency decides, the questions have not landed.

• Count the cash and the third-party payers. A buyer who never pays from their own account is a fact about the book, not a story for later.
• Count company and trust buyers. Each one is a KYB question. The sales consultant's impression of the director is not the count.
• Ask the proliferation question in words. PF is not a footnote under money laundering. Give it a line and an answer.
• Name who can stop exchange. A principal who will not delay a campaign is a risk decision, and the assessment should say so.

Questions for this agency's book

Where the agency questions stop

This page is the agency's ML/TF/PF question list. It is not the definition of the customer, and it is not the whole real estate program. Those are who is the customer for real estate AML and real estate AML compliance.

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 agency's risk answers are not the buyer's check, and that check is client-pays when the program requires it. Confirm the live amounts on FreeAML pricing. FreeAML does not answer the agency's risk questions or approve the assessment.

Frequently Asked Questions