Related-party sale under market: SMR or a file note?

People search “related party sale under value AML” when a suburban agency sees a family sale well under the campaign price and wants the note to stand in for a report. Checked against AUSTRAC’s suspicious matter reports page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. How a report is lodged, if you form a suspicion, is the SMR filing guide. What you do not tell the parties is what not to tell a client. The sector map is /tranche-2.

The note and the report are different duties

An agency can have a sound reason for a related-party price, such as a marriage split, an estate, or a tenant buying the home they live in, and it can also have a price nobody can explain. The program should already treat an unexplained gap, and a sale between related parties, as a prompt. AUSTRAC’s suspicious matter page is the report frame. This page does not reproduce it.

Write the facts you can point at, and do not write a conclusion you have not made or language aimed at avoiding a report. If the named person forms a suspicion, the reporting duty is separate and the note does not discharge it. You also do not tell the parties that a report is being considered.

• Record the relationship. Parent and child, spouses, a company and its shareholder. “Related” with no names is not a note.
• Record the gap you can see. Compare the contract with the campaign or the appraisal already on the file. Do not invent a valuation.
• Record the explanation you accepted, if you accepted one. A blank “commercial decision” is not an explanation. If you do not accept it, say that the suspicion question is open.
• Keep the report off the sales desk. Lodging is the filing guide’s subject. This page does not describe the form, the portal, or a form of words.

Note, report, or neither yet

Staff argue these as if they were moods. They are records. Pick the record that matches the decision you have actually made.

Where the under-market page stops

This page separates the note from the report. It is not the lodging guide and it is not the tipping-off rule. Those are the SMR filing guide and what not to tell a client.

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. Choosing between a note and a report is the firm’s decision, and that decision is not included in the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not decide whether you have a suspicion or write your file note.

Frequently Asked Questions