Who is the customer on a real estate sale?

One sale, four firms, different customers

The contract has two sides. The AML customer is the person your designated service is provided to, and for a real estate broking service AUSTRAC’s kit is explicit: successful broking makes both the buyer and the seller your customers. That sentence does not automatically become the conveyancer’s customer list, or the solicitor’s. Each firm applies the test for the service it provides. The public map of sectors is /tranche-2.

The buyer’s-agent row is argued in this forum thread. The dedicated answer is do buyer’s agents verify the seller?. Forms Live on CDD and VOI is the reminder that the person who attended the inspection is not the definition of the customer.

Why the conveyancer is not on the agent’s list

Real estate broking and professional assistance with a transfer are different designated services. Lex AML’s Table 6 explainer sets out the professional items and, for assisting a real estate transaction, identifies the customer as the person assisted. Real estate agents sit in the real estate table, which is why the starter kit speaks to agencies. Use Lex as orientation and read the Act. Do not lift the agent’s “both parties” line into a conveyancing costs agreement unless your own service actually covers both parties.

Two firms can still collect the same passport if they never speak. Agree who is collecting what, and tell the client. Reliance, where your program allows it, is the alternative to a second check. The agent workflow on this site is AML checks for real estate agents.

Prove the choice

A September 2026 Queensland Law Society Proctor article makes the enforcement point for law practices: once the regime is live, the hard question is whether the firm can show what it decided. The same discipline helps an agency. On the file, a reviewer should be able to see who you treated as the customer, why, what customer due diligence you hold, and the risk rating. AUSTRAC’s initial CDD overview is what that record has to be able to support.

• One sentence on the matter: who the customers are for this service.
• The check outcome for each of them, or the reliance record.
• The risk note, including a company or trust behind a name on the contract.
• Who paid, which is a commercial fact and not a substitute for the customer sentence.

The person who pays is the customer you named

Once the customer is clear, that is the person who can pay their own verification. On FreeAML the firm suite is A$0 and verification is client-pays. Amounts are on /pricing. Seller-side money for buyer’s agents is how the cost is handled. Send the request by email so the customer list and the invitation match. Start at /aml-check.

Frequently Asked Questions