Clarity Over Complexity:AML Made Practical for Real Estate & Conveyancing

We're here to talk about one of the biggest issues in real estate at the moment — the new AML regulations. While much has been made about the obligations of agents and how much work that's going to require, proptech like Forms Live have been working behind the scenes to make this as easy as possible. Our goal is to make this webinar as practical as possible, so you can come away with a good understanding of how AML is going to impact you — and more importantly, how it's going to impact your workflows. David, let's kick off with an overview. What's the current state of play?

Until recently, there's been very little you've had to do around verifying buyers and sellers and customer due diligence. Tranche 1 introduced verification of identity — something finance and other industries were already doing. Tranche 2 is about extending that due diligence so you have a better picture of who your customers are.

This process happens in parallel to your day-to-day. In most cases, it shouldn't impact your standard workflows. There'll be a couple of staff who handle the compliance piece, but from a selling agent's perspective, there's very little additional work if you're using Forms Live.

Why is real estate being singled out?

Real estate isn't being singled out. Tranche 2 includes precious gems dealers, accountants, conveyancers, and a number of other sectors. Between 2019 and 2024, there was over $720 million worth of real estate seized by the government due to money laundering and crime-related transactions. It's a genuine risk — and Tranche 2 is about reducing it.

What would the red flags be for agents — the signals that a transaction is suspicious?

Tranche 2 has two components. First, as a principal, you need to set out your business's policies and procedures. For example, you might decide not to accept a physical cash deposit over $5,000, or you might rule out cryptocurrency. These are your stated risk thresholds.

Separately, when you go through the CDD process with a specific buyer or seller, certain results might flag — for example, if someone appears on a politically exposed persons (PEP) list. That's when you'd report to AUSTRAC.

Are there draft policies or templates you can use to get started?

Yes — AUSTRAC has released a starter pack you can use as a template. Most of the policy decisions are straightforward: limits on physical cash, no cryptocurrency, basic due diligence thresholds. One of our integration partners, easyAML, also has those policies and procedures built into their platform and is currently offering free registration until July — a useful way to understand what's required before committing to a provider.

I break Tranche 2 into two components. PDD — personnel due diligence — covers your policies, procedures, and staff training. This is what you need sorted before July. Then there's CDD — customer due diligence — which is your day-to-day transaction process from 1 July onwards.

Which AML providers are you integrating with, David?

Our current integrations include easyAML, First AML, AMLHUB, Securexchange, and APLYiD. We vet each provider carefully, so if it integrates with Forms Live it's worth a look. Larger agencies will likely suit a subscription model with easyAML, First AML, or AMLHUB. For smaller or lower-volume needs, Securexchange offers a pay-per-verification model. In most cases, you'd bundle that cost into your administration fees.

If someone turns up with a duffel bag of cash and you say you can't accept it — do you still have to report it?

No — because at that point you haven't gone through the CDD process. Your policy says you don't accept it, so you simply decline. The reporting obligation only applies once you're further into the due diligence process and a red flag comes up — for example, if someone comes back as a politically exposed person during their identity check.

Reporting to AUSTRAC doesn't stop your transaction. You're flagging it for them to investigate — you're not making the judgment call yourself. In the vast majority of cases, you'll complete CDD and never need to report anything.

What are the risks if you don't report a suspicious transaction?

You must report — full stop. There are fines for both the agent and the principal, and they are significant. AUSTRAC is working collaboratively with the industry as this rolls out, and they understand it's new to everyone. As long as you're making a genuine best effort to verify buyers and sellers and maintain records for auditing, you're covered.

VOI — verification of identity — is about proving the person you're dealing with is who they say they are. It doesn't tell you if they're involved in a crime; it just confirms their identity against government records.

In Forms Live, you initiate a VOI, the buyer or seller receives a link, and they complete it on their mobile — uploading a driver's licence, passport, or Medicare card, and taking a live photo. The system checks everything against government databases. Our AML providers also run liveliness checks to prevent AI-generated fake images from passing.

For auctions — do you have to verify all registered bidders?

No — only the winning bidder. You sign the contract at auction, start the CDD process in parallel, and have 15 days to complete it. The same principle applies to private treaty; the process doesn't interrupt the transaction.

For sellers: once you've verified a vendor, you don't need to re-verify them — unless more than two years have passed. For a developer with multiple properties, each buyer needs individual verification, but the vendor only needs to be verified once.

I'm opening a standard Victorian Sales Authority — a form I'd use any day of the week. While it's in draft, I can start the AML CDD process. Or I can do it after the form has been sent for signing. The flexibility is there.

In Connections, I select easyAML and log in. Because I've done this once before, it auto-connects. The first time, it simply asks if you want to allow Forms Live to connect to easyAML — you say yes, and it's done. You don't need to do that again.

The form has already pulled out the vendor's details automatically. I explain to the customer that I need to go through the verification process, and I initiate it with a single click. That's it. As a selling agent, my job is done. The customer receives a link on their phone, completes the process themselves, and I can track the status from my dashboard.

So it's one click for the agent?

One click. In more complex cases — companies, trust structures — the compliance officer may need to do additional work. But for a standard residential sale, that's the agent's entire involvement. The dashboard shows PEP checks, sanctions, adverse media — but agents don't need to drill into any of that. They just need to know if the process is complete.

If you'd rather not use an integrated provider, we have our own forms for individual and company onboarding — based directly on the AUSTRAC starter pack. You can send these to customers via our Info Request feature so they complete the details themselves, including attaching their identification documents.

So if you go this route, you're not paying a subscription or transaction fee to an AML provider. But you're then responsible for your own audit trail?

The audit trail remains in Forms Live, so that's covered. What you're not getting is full automation. This is the more basic scenario — the integrated providers give you a complete, automated solution.

And yes — if you go manual, you will end up with identity documents stored somewhere. Forms Live is ISO 27001 compliant, so storage within the platform is fine. But if you're printing and filing passport copies, that's where the data risk sits.

The Forms Live app is coming out very soon. It gives agents a mobile view of all forms currently out for signing. We're adding a KYC tab — so you can see at a glance where each customer is in the verification process. Think of it like electronic signing status tracking, but for identity and due diligence. You'll be able to see who's completed it, who's still outstanding, and follow up from your phone without opening the full platform.

So this isn't specifically for AML, but it's a new tool that will help agents stay on top of it while they're out on the road?

Exactly. KYC and KYB — know your customer, know your business — as an umbrella across the whole process. Particularly useful if you have a compliance officer at the office handling complex cases; agents can see where things are at without having to call in.

1. Read the AUSTRAC starter pack and set your policies. Focus on the sections relevant to real estate. Set your thresholds — physical cash limits, cryptocurrency policy — and document them.

2. Sign up to easyAML for free before July. It's a useful way to understand what the CDD process looks like in practice, even if you later choose a different provider. They guide you through exactly what you need as a principal.

3. Do a test run before July. Once your policies are in place, do a dry run so your team is comfortable before it's live. There's no need to wait until 1 July to get familiar with the process.

Change is always awkward until it becomes familiar. Countries like New Zealand are already doing this — it's business as usual for them. The goal between now and July is to get as familiar as possible with what's coming, so that by the time it's live, it already feels routine.