Services for real estate agencies
AML customer due diligence for real estate agents, under a reliance agreement
Tranche 2 brings real estate agencies into the AML/CTF regime from 1 July 2026. Rather than building verification capability in-house, your agency can rely on customer due diligence carried out by our law practice under a written reliance agreement — and get a compliant record back the same day.
What we provide
- Written reliance agreement drafted for your agency
- Electronic identity verification of individuals
- Company, trust and beneficial ownership checks
- PEP and sanctions screening
- Source of funds enquiries where the risk rating requires them
- Compliant, retained records available to your office and to AUSTRAC
- Escalation and suspicious matter guidance from a solicitor
- Agent and staff briefing on what to collect at listing
Why reliance rather than in-house
Doing it in-house means training every sales agent to collect and verify identity documents, buying a verification platform, storing sensitive identity data securely for years, and having someone in the office who can tell the difference between an awkward client and a suspicious matter. For a small or mid-size agency that is a disproportionate amount of machinery for work that a law practice already does on every conveyance.
Under the arrangement your agency stays the reporting entity and keeps its own enrolment, program and compliance officer — reliance covers the customer due diligence limb, properly documented, so the checks are done once by people who do them daily.
The other thing agents ask us for
Most agencies that set up a reliance agreement also hand us their Form 2 seller disclosure packs, so the listing goes to market compliant on both fronts.
Who your agency deals with
Michael Klein
Legal Practice Director
Admitted 2003. Based in Redcliffe, Moreton Bay.
Read Michael's profile
Questions agency principals ask about AML
What are the new AML obligations for real estate agents in Australia?
From 1 July 2026 real estate agencies are reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act as part of the tranche 2 reforms. That means enrolling with AUSTRAC, having an AML/CTF program, appointing a compliance officer, carrying out customer due diligence on the parties to a designated service, and reporting suspicious matters.
What is a reliance agreement?
The AML/CTF regime lets one reporting entity rely on customer due diligence carried out by another reporting entity, under a written agreement, instead of duplicating the work. Because law practices are also reporting entities, an agency can enter a reliance arrangement with us: we carry out and record the identity verification and due diligence, and the agency relies on it rather than building the capability in-house.
What does Coastside Law actually do under the arrangement?
We verify the identity of the seller (and, where the agency's designated service requires it, the buyer), check beneficial ownership for companies and trusts, screen against politically exposed person and sanctions lists, record the outcome, and give the agency a compliant record it can produce to AUSTRAC. Records are kept for the statutory retention period and are available to the agency on request.
Does reliance transfer our liability to you?
No — and be wary of anyone who says it does. Under a reliance arrangement the agency remains the reporting entity responsible for its own obligations; what reliance does is let you use our due diligence rather than repeating it, provided the agreement, the checks and the record-keeping meet the requirements. We set the agreement up so those conditions are properly documented.
How does it work day to day?
The agent sends us the listing or contract details. We contact the party directly, run the verification electronically (usually the same day), and return a completed due diligence record to the office. In a conveyancing matter we are already verifying identity for the transaction, so for many agencies the marginal cost of the AML work is small.
What does it cost?
We quote a fixed per-party fee, and a lower per-matter rate for agencies that send us their conveyancing work as well. Call 0488 340 853 and we will put a proposal and a draft reliance agreement in front of you.
Eight weeks into tranche 2 — how is your agency actually going?
Call 0488 340 853 for a no-charge review of how AML is running in your office, and what a reliance agreement would cost.