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Compliance
October 4, 20269 min read

Third-party payer of the deposit

A third party who pays the deposit is not automatically the customer. The payment is a source-of-funds question the program should already have a line for.

Quick answer

On settlement week, record who paid, whether they are the buyer, and the explanation the program asks you to seek, and do not receipt the money with a blank note. Who the customer is remains the program’s customer rule. This page does not list proof documents and it does not reproduce enhanced due diligence guidance. The client pays any check the program requires.

People search “third party deposit AML” when a conveyancer on a settlement sees the deposit arrive from an account that is not the buyer’s. Checked against AUSTRAC’s enhanced customer due diligence reform page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The conveyancer’s own service is AML for conveyancers assisting a transfer. Who the customer is on a property file is who is the customer on a real estate file. The sector map is /tranche-2.

The payer is a fact on the receipt

Conveyancers see deposits from parents, from a related company, and from an account name that matches nobody on the contract. The customer is still whoever the program says is the customer, often the buyer, and the payer is a source fact. Enhanced due diligence is where a program puts the harder source questions. This page does not reproduce that guidance and does not set a document list.

Write the payer’s name as it appears on the receipt, the buyer’s name as it appears on the contract, and whether they are the same person. If they are not, follow the line your program already wrote for third-party money. A blank receipt with “deposit received” is the failure. Inventing a rule that every payer becomes a second customer is a different failure.

  • Match the names. Contract name against payment name. A near-match is still a question. Write both strings.
  • Use the program’s source line. The question is where this deposit came from. It is not a new identity product you design at the trust account.
  • Do not promote the payer to customer by default. Customer status comes from the program. A generous parent is not automatically a second buyer.
  • Do not ignore a company payer. If a company paid, say so. Whether that company is itself in scope is the program’s question, not a guess from the account name.

Buyer, payer, customer

Three roles can sit on one deposit. The settlement file should show which role you mean before anyone orders a check.

A sorting aid for a deposit on settlement. This table does not reproduce AUSTRAC’s enhanced CDD guidance.

RoleWhat you recordWhat you do not assume
Buyer on the contractThe program’s customer, if the program says soThat they paid, without looking
Payer of the depositThe name on the receipt, and that it may differThat they are now the customer
Same person in both rolesOne name, noted as the sameA second check to look busy
A company or relative who paidThe source question the program already wroteA document list invented on the day

Where the deposit page stops

This page is the third-party payment. It is not the conveyancer’s service test and it is not the general customer definition. Those are AML for conveyancers assisting a transfer and who is the customer on a real estate file.

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. Recording a third-party payer is file work, and that note is not a check included in the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a third-party deposit is acceptable or name the payer as the customer.

Frequently Asked Questions

Note the payer. Email a link only if the program requires a check.

The firm suite is A$0. The client pays the check the program names. A deposit receipt is not that check.

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Questions: team@freeaml.com.au