Buyer and seller use the same firm: two customers, two CDD files
If the buyer and the seller use the same firm, they are two customers with two due diligence files. A conflict check is not that file.
Quick answer
Professional rules about acting for both sides are a separate question, and this page does not answer them. Where the firm does act for both, the program still treats each customer on that customer's facts, so do not copy the buyer's check onto the seller. The firm emails each customer the link that file needs. Each client pays for the check on their file.
People search “same firm both parties AML” when a two-partner firm is asked to act for both parties on one transfer and wants a single CDD pack. Checked against AUSTRAC's initial customer due diligence overview on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Who the customer is, for an agency, is who is the customer in real estate. The sector map is /tranche-2.
One firm is not one customer
Same firm both parties AML comes up on a small transfer where both sides trust the same office. The convenience is real. The customer is still whoever your program says is the customer for the service you are providing to that side. Opening one folder called 'the matter' hides which facts belong to whom.
A person who is a director of the buyer and a shareholder of the seller can appear on both files, for different reasons. One personal check is not a reason to skip the second role. Record why the name is there each time.
- Open two files. Buyer and seller each get the customer due diligence your program sets for that customer. A shared index is not a file.
- Keep the conflict question next door. Whether you may act for both is a professional-rules question. It does not collect KYC information.
- Do not copy documents across. The buyer's result is not the seller's result. Send the seller their own link.
- Price them separately. Two personal checks are two client-pays KYC checks. They are not a couple's discount inside one company KYB.
What goes in which file
A sorting aid when both parties sit in the same waiting room. This table does not reproduce AUSTRAC's initial CDD overview.
| Party | The file | The mistake |
|---|---|---|
| Buyer | The buyer's CDD, on the buyer's facts | One pack labelled the matter |
| Seller | The seller's CDD, even if the same staff act | Pasting the buyer's result onto the seller |
| A person on both sides | A name can appear twice, for two reasons | Assuming one KYC covers both roles |
| The conflict note | A professional-rules record | Calling that note customer due diligence |
Where the both-parties page stops
This page is the two-file rule inside one firm. It is not the general shape of customer due diligence. That sits on AUSTRAC customer due diligence. This page does not say you may act for both sides.
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 second party is not included in the first party's check, and a joint file is not included in the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not decide whether you may act for both parties, or merge their customer due diligence.
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Frequently Asked Questions
Two customers. Two links.
The firm suite is A$0. The client pays. Send each customer the check your program requires for that file.
Start an AML checkQuestions: team@freeaml.com.au