Seller evidence and reliance — current correction
A VOI, Securexchange, PEXA or selling-agency identity report is normally supporting evidence first, not automatic reliance. “Trusted, licensed and the name matches” is not enough by itself.
Use the updated route guide to distinguish direct verification, evidence plus top-up, case-by-case reliance, an ongoing written CDD arrangement, a Rule 6-33 same-transaction arrangement and actual Seller non-cooperation:
For the 9 Sandon Place file, the RE/MAX remote VOI is Route 2A supporting evidence. The solicitor’s request for the legal basis and Seller authority is not Seller refusal. Complete the missing CDD and obtain Compliance approval before finalising the Seller check.
Start here — the plain-English version
Buyer check: complete Buyer CDD before InvestorKit starts the buyer’s-agency brokering service.
Seller check: start the property-linked Seller workflow when the purchase is reasonably expected to proceed—usually when the offer is accepted and the contract is signed.
For a Seller check, staff only need to remember this process:
- Open the correct Seller check in InvestorKit Engage.
- Confirm every legal Seller, their capacity, the property, exchange date and the initially agreed settlement date.
- Choose one route:
- Direct secure check: the Seller completes AML Partners verification.
- Approved third-party CDD: the selling agency, solicitor or conveyancer supplies suitable KYC and verification data through a secure, Compliance-approved process.
- No access or refusal: record all reasonable steps, identify who blocked access and request Compliance review.
- Do not email identity documents.
- Do not treat an invitation, upload, screenshot, VOI certificate or “Seller verified” email as clearance.
- Complete the check as soon as reasonably practicable. If delayed counterparty CDD is lawfully used, the outside deadline is the earlier of 28 days after exchange or 3 days before the initially agreed settlement date.
- Wait for the final Compliance decision in Engage.
Use these two short guides before the detailed stage-by-stage FAQ:
InvestorKit Engage is the place where AML work is done
- Open the agreement and its linked Buyer or Seller check.
- Save routine case notes, refusals, requests and securely received files on that check. Keep suspicions and SMR information in the restricted Compliance channel.
- Choose Request Compliance review in Engage when a person must decide.
- AML Partners performs the provider checks. InvestorKit records its own decision in Engage.
- Email is only a backup alert. It is not the compliance record.
Live staff tools: Open AML guides and replies
Notion authoring source: Open the approved AML email template database
Safe public link: Share the Seller verification guide
Only entries marked Approved, Publish to Engage, External safe and Tipping-off safe may be considered for Engage. Editing Notion does not publish anything automatically.
Do not bypass InvestorKit Engage
- Do not create a Buyer or Seller case directly in AML Partners unless Engage tells you to.
- Do not manage a check from email, WhatsApp, a spreadsheet or a general Attio note.
- Do not email identity documents.
- An invitation, upload or provider email is not clearance.
- If Engage is unavailable, or private information went to the wrong place, use compliance@investorkit.com.au as the emergency path.
What starts when
- Buyer CDD is a pre-service requirement. AUSTRAC says a buyer's agent starts providing the designated service to the Buyer when the agreement to find or identify a property is signed. InvestorKit must complete Buyer CDD before that point unless Compliance has documented a separate lawful delayed-CDD basis.
- Engage may use signing, Identity or confirmed payment as workflow triggers, but those system events do not change the legal timing. Do not search, present, negotiate, submit offers or provide other client-specific brokering work until the current Buyer is Cleared, or Compliance approved No check needed. If the current workflow starts Buyer CDD only after signature, treat that as a control requiring Compliance and legal review—not as proof that the timing is compliant.
- The agreement's Purchase Type is the buying-structure source of truth. A real change means stop and review.
- A date before 1 July 2026 is not an automatic exemption. Compliance decides.
- Start the Seller workflow once the transaction is reasonably expected to proceed. For most sales, this is when the Buyer's offer has been accepted and the contract is signed. See AUSTRAC's real estate guidance.
- Complete Seller CDD as soon as reasonably practicable. InvestorKit aims to finish within 15 days after exchange, or earlier if settlement requires it. This is an internal target, not the legal outside deadline.
- If delayed counterparty CDD is lawfully used, the outside deadline comes from section 29 of the Act and Rule 6-32: the earlier of 28 days after exchange or 3 days before the initially agreed settlement date. Do not wait until then. See AUSTRAC's delayed CDD guidance.
- Rule 6-33 is separate. It covers a limited same-transaction information-sharing arrangement and the special non-cooperation pathway; it is not the source of the Rule 6-32 outside deadline.
- Engage tracks and warns. It does not itself block an Attio stage move, exchange or settlement.
Two AUSTRAC anchors
“both the buyer and seller ... will be the customer of the same reporting entity”
“Reliance isn’t the same as outsourcing or agency arrangements.”
Need help?
- For a normal case, add the facts to the linked check and request a review in InvestorKit Engage.
- For AML Partners technical help, use support@amlpartners.com.au.
- Use compliance@investorkit.com.au only if Engage is unavailable or there is a privacy or security incident.
Read the right record
- Attio agreement stage:
agreements.agreement_statusshows the commercial stage, such as Agreement Sent, Agreement Signed, Onboarding, Searching, Submitted Offer, Offer Accepted, Exchanged or Settled.
- Engage client steps: Details, Sign, Payment and Identity are customer tasks. They are not the same as the Attio agreement stage.
- Buyer AML result: the linked
compliance_checksrecord is the check record. Its outcome rolls up to the agreement. Engage displays the status but does not decide or certify it.
- Seller work: staff use the Engage Seller workflow. It reads
properties_selectedbefore Exchange andproperty_purchasedfrom Exchange onward when available.
- Contract or accepted offer: use the actual document for purchasing capacity, deposit, conditions, the initially agreed settlement date and solicitor or conveyancer details. These facts are not all visible in Engage.
📘 Key terms
- Buyer: who buys the property.
- Seller: who sells it.
- Entity: a Company, Trust or SMSF.
- CDD: the required customer identity, ownership and risk check.
- InvestorKit Engage: the staff and client gateway for agreements, onboarding, payment and Buyer/Seller compliance workflow.
- InvestorKit EDGE: research, content and collaboration. It is not AML clearance or an AML evidence store.
- AML Partners: InvestorKit’s outsourced verification provider. Outsourcing does not transfer InvestorKit’s responsibility and is not reliance.
- Attio: holds linked agreement, property and compliance records.
- Ordinary reliance: specified KYC collection or verification performed by an eligible reporting entity or eligible foreign equivalent under sections 37A or 38 and Rules 6-29 or 6-31. It must be appropriate to InvestorKit's risk and does not transfer InvestorKit's remaining duties.
- Rule 6-32: the real-estate delayed-counterparty CDD rule. For InvestorKit as the Buyer's agent, it concerns the Seller and sets the earlier-of-28-days-or-3-days-before-initial-settlement outside deadline, subject to section 29's conditions.
- Rule 6-33(1): a special same-transaction arrangement with another participating reporting entity. It can deem only specified section 28(2) matters established; InvestorKit still takes reasonable steps on an individual Seller's identity, identifies its own risk and collects risk-appropriate KYC.
- Rule 6-33(3): the provision relevant to InvestorKit where the actual Seller does not cooperate. InvestorKit must take all reasonable steps, record the steps and difficulties, and record its consideration of any SMR obligation.
- AUSTRAC Request to verify information form: a starter-kit document that may help propose a Rule 6-33 arrangement. It is not legally mandatory, and sending or partly completing it does not create an arrangement.
- SMR: Suspicious Matter Report. Never reveal one or a related suspicion.
👥 Who checks whom, and how InvestorKit Engage is used
One operating model
- Owner: the InvestorKit staff member responsible for the agreement.
- Through Engage: open and track the correct Buyer or property-linked Seller workflow. Engage routes approved provider actions to AML Partners and records InvestorKit’s own steps.
- Complete when: the correct role, agreement, property, provider status and Compliance decision are visible.
- Stop when: a link, role, party, structure or decision is missing or wrong.
flowchart LR
A[Buyer or Seller] --> B[InvestorKit Engage gateway]
B --> C[AML Partners provider checks]
B --> D[InvestorKit evidence and workflow]
C --> E[InvestorKit Compliance decides]
D --> EChecklist
Common questions
Q: What does the external selling agent do?
It represents the Seller commercially.
If it brokers the sale, both the Seller and Buyer are its customers for AML/CTF purposes.
It checks the Seller when its agency service begins and checks the Buyer when the sale is likely to proceed.
It makes its own decision. It does not receive InvestorKit's ID, screening, risk or internal notes unless Compliance approves a formal arrangement.
Q: What does InvestorKit do as the buyer's agent?
We represent the purchaser under the buyer's-agency agreement.
Staff may communicate with third parties, provide authorised factual purchaser and transaction details, and support the purchase through settlement.
Staff must not sign or execute another document for the purchaser, certify facts they cannot personally confirm, or disclose InvestorKit's AML Partners evidence without an approved basis.
We must complete Buyer CDD before starting the designated brokering service. AUSTRAC says this generally starts when the buyer's-agency agreement to find or identify property is signed—not merely when tailored property work begins. When the sale is reasonably expected to proceed, the SSC manages InvestorKit's separate Seller check for that property.
AML Partners performs the checks. Compliance makes InvestorKit's decision.
Q: What exactly is InvestorKit Engage?
It is our signing, onboarding, payment and compliance portal.
Customers complete their journey there.
Staff manage linked work.
It does not replace AML Partners or Compliance.
Q: How does a staff member use InvestorKit Engage?
Open the agreement in InvestorKit Engage.
Open the linked Buyer or Seller check.
Tick the checklist, add notes or secure files, and use the action shown.
Use the live guides and reply templates.
Do not create duplicate cases.
Use the AML Partners staff portal only when Engage directs you there.
If the linked check is missing, stop. Confirm this in the AML hub. If it is truly missing, use the emergency email path because there is no safe check to record the issue against.
Q: What is tipping off, and what must staff not say?
Tipping off means revealing a suspicion or SMR in a way that could harm an investigation.
Never reveal suspicion, SMR, screening, risk or internal review.
Say check required, in progress, more information needed, under review or unable to proceed.
📝 Agreement Sent, Agreement Signed and onboarding tasks
Prepare the Buyer record and follow the next Engage task
- Owner: the staff member sending and following up the agreement.
- Through Engage: confirm legal Buyers, Purchase Type, entity facts, signing, Payment and Identity.
- Complete when: the agreement is signed, the real purchasing structure is clear and the customer follows the next task shown in Engage.
- Stop when: signing, structure or the linked Buyer record is missing or guessed.
What the customer actually sees
This is the real Engage customer dashboard using a fictional demo agreement. It shows the next required task without exposing staff-only AML notes or provider evidence.
Real Engage demo: the customer sees the agreement steps and the next action.
flowchart LR
A[Client opens Engage] --> B[Signs agreement]
B --> C[Engage shows next task]
C --> D[Payment]
C --> E[Identity when available]
E --> F[Linked Buyer check]Checklist
Common questions
Q: When must the Buyer AML check be completed?
The legal requirement is to complete initial CDD before InvestorKit starts providing the Buyer with the designated brokering service. AUSTRAC says a buyer's agent generally starts that service when the agreement to find or identify a property is signed.
Engage may operationally trigger the workflow from signing, the customer's secure Identity submission or confirmed payment. Those workflow triggers do not extend the legal deadline. If Identity is not available until after signature, do not assume the process is compliant: stop client-specific brokering work and obtain a Compliance decision on the lawful timing and any documented delayed-CDD basis.
Staff must not create the AML Partners case directly.
Q: What should we collect before Identity?
Collect each Buyer's legal name, approved contact details and intended Purchase Type.
For a Company, Trust or SMSF, also collect the entity name, ABN or ACN and the people who own or control it.
Date of birth, residential address and evidence belong in the secure Identity process.
Q: The buying structure is not decided yet. What do I enter?
Do not guess.
Do not choose Personal just to move forward.
Record that it is undecided and resolve it before the AML check starts.
Q: How do I explain the identity check to a prospect?
Say: “We must complete the required identity and ownership checks before we start providing our regulated buyer's-agency service. Please complete the secure Identity step when Engage presents it. AML Partners will send the verification request, and a Company, Trust or SMSF may need extra information.”
✍️ Buyer Identity and linked check
The Buyer check now runs through Engage
- Owner: the staff member responsible for the Buyer check.
- Through Engage: open and track the linked Buyer compliance record; Engage routes approved verification to AML Partners.
- Complete when: every required Buyer and entity is Cleared, or Compliance approved No check needed.
- Stop when: the record, invitation, person, entity or structure is missing or wrong.
What the customer actually sees
Engage explains why the check is required and that AML Partners sends the separate secure verification request. Completing the Engage step is not the same as clearance.
Real Engage demo: customer Identity step and AML Partners hand-off.
flowchart LR
A[Identity submitted or payment backstop] --> B[Linked Buyer compliance record]
B --> C[AML Partners secure request]
C --> D[Buyer completes verification]
D --> E[Engage shows provider status]
E --> F[Compliance decides]Checklist
Common questions
Q: What happens now?
After Engage opens and links the Buyer check, AML Partners sends each required Buyer a secure request.
Companies, Trusts and SMSFs also need their entity and controlling people checked.
If nothing starts, use the problem steps later on this page.
Q: The client signed and paid before 1 July 2026. Are they automatically exempt?
No.
A pre-commencement relationship may fall within transitional rules, but a date alone is not a staff decision.
Current automation may allow some pre-1 July records with blank clearance to progress. That is a system-control gap, not proof of exemption or Compliance approval.
Email the agreement facts to compliance@investorkit.com.au.
Q: Is an email showing the old signing and payment dates enough?
No.
It helps Compliance review the facts, but it is not clearance.
Do not attach identity documents.
Q: The client is one of our own staff. Can we skip it?
No.
Staff follow the same checks and stage rules.
Q: What messages does the client get when the AML check starts?
After the linked Buyer check starts through Engage, AML Partners sends the Buyer an email and text message.
It may also send reminders:
🛂 Onboarding (checks running)
Use Engage as the live status and action gateway
- Owner: the staff member responsible for the Buyer check.
- Through Engage: follow the linked AML Partners status, requests and current Compliance decision.
- Complete when: all required person and entity checks are complete and Compliance records the decision.
- Stop when: anyone is missing, details changed, or the provider result still needs review.
flowchart LR
A[AML Partners collects and checks] --> B[Engage shows linked status]
B --> C{Everyone complete?}
C -->|No| D[Wait or fix scope]
C -->|Yes| E[Compliance reviews]
E --> F[Engage shows final status]Checklist
Common questions
Q: The client asks “Is this link legitimate, and why do I need it?”
Say: “Yes. AML Partners is our secure verification provider. Complete its request before we start property work for you.”
Q: What does the client need to do?
Complete the AML Partners request.
Use accurate details and clear documents.
Every Buyer must finish their own part.
Reply quickly if AML Partners asks for more.
Questions: Buyer scope and entity checks
Q: There is more than one purchaser. Is one check enough?
No.
Every required Buyer must complete their part.
Q: They are buying through a Company, Trust or SMSF. What is different?
We check the entity and the people behind it.
This may include trustees, directors, representatives, owners and controllers.
Q: The link expired or the client has a document problem. Who helps?
Try a current browser, clear photos and good lighting.
If that fails, email support@amlpartners.com.au.
Never tell a client they “failed.”
Questions: provider status and Compliance decisions
Q: What can InvestorKit staff see and decide?
Staff can help with Engage, agreements, payments and the process.
AML Partners performs checks.
InvestorKit Compliance makes the final decision.
Never share screening or risk details outside Compliance.
Q: What do Low, Medium, High or extra-review results mean for me?
They guide Compliance.
They are not client-facing labels.
Wait for the final status in InvestorKit Engage.
Q: Can the client use InvestorKit Engage or InvestorKit EDGE (Client Portal) while AML is pending?
Yes, for signing, payment, general content and collaboration.
Portal access is not AML clearance.
Do not start tailored research, searching, offers or settlement support.
Questions: changes and moving to property work
Q: What happens when Buyer details change?
A recorded purchase-structure revision can reopen the Engage AML step. It does not prove that AML Partners received a fresh check for the right people and entity.
A real change to names, Purchase Type, entity, ABN, ACN, owners or controllers means stop and obtain a Compliance decision.
Filling a harmless empty field may not require a re-check.
Staff must compare the new facts with the provider parties and current clearance. Do not assume automation completed the re-check.
Q: When can I move the client to Searching or Presenting?
Only when the current Buyer and structure show Cleared, or Compliance approved No check needed.
🔍 Searching / Presenting
Engage shows status; staff still compare the legal facts
- Owner: Brief Assigned To and Strategist.
- Through Engage: open the linked Buyer status and any recorded purchase-structure revision.
- Complete when: staff confirm the current legal Buyer and structure still match the provider parties and Compliance decision.
- Stop when: names, structure, entity or linked clearance changed.
flowchart LR
A[Searching starts] --> B[Staff compare Buyer and Purchase Type]
B --> C{Matches the cleared check?}
C -->|Yes| D[Searching may continue]
C -->|No| E[Re-check needed]
E --> F[Stop client-specific work]Checklist
Common questions
Q: Can I start while the check is in progress?
No.
Wait for Cleared or approved No check needed.
Q: What happens if I move an uncleared deal to Searching?
Engage does not block the stage move.
A database automation may alert staff or reverse the stage. Treat that as a hard stop. Even without an alert, open the linked check and confirm the current Buyer is Cleared before tailored work.
Q: The client changes from Personal or Joint to a Trust, Company or SMSF while we are Searching. What do I do?
Stop work.
Do not only edit Attio.
The client must confirm the entity details in InvestorKit Engage, sign the amended agreement and complete the new AML Partners check.
Work stays paused until the new legal Buyer is cleared.
Q: Will InvestorKit Engage catch a structure change after the deal is already in Searching?
A recorded purchase-structure revision can reopen the Engage AML step and notify staff.
Engage does not compare purchaser names or Purchase Type against the AML Partners parties, and kickoff may still return the existing provider deal.
Staff must compare the live facts and obtain Compliance confirmation before work resumes.
Q: The client is chasing me. What do I say?
Say: “Your check is still being completed. We can begin tailored property work once the current Buyer details are cleared.”
Do not share risk or screening information.
Q: InvestorKit EDGE (Client Portal) is open. Can I start client-specific research?
No.
InvestorKit EDGE gives content and collaboration access.
It is not AML clearance.
🤝 Submitted Offer
Engage shows status; staff perform the comparison
- Owner: Brief Assigned To.
- Through Engage: open the linked Buyer status and selected property.
- System limit: Engage does not block the Submitted Offer stage and does not compare purchaser names or Purchase Type.
- Staff must check: the offer, signed agreement, property, purchaser names, purchasing structure and linked cleared check.
- Stop when: any legal Buyer fact, structure, property or clearance differs.
flowchart LR
A[Submitted Offer] --> B[Open Engage status and property]
B --> C[Staff compare offer and signed agreement]
C --> D{Everything matches and Buyer Cleared?}
D -->|No| E[Stop and fix]
D -->|Yes| F[Offer may proceed]Checklist
Common questions
Q: What happens when I move an agreement to Submitted Offer?
Engage shows the linked Buyer status and selected property. It does not perform the comparison or block the move.
Staff must compare the legal Buyer names, Purchase Type, entity wording, property and offer against the signed agreement and linked cleared check.
If any fact or clearance is wrong, stop and fix it.
Q: Can I rely on automation without checking the Buyer details?
No.
Automation can be missing, stale or incomplete.
Compare the offer, signed agreement and linked Buyer check by hand.
Q: Before the offer is accepted, the client says, “Put it in my new Trust.” What do I do?
Stop the offer.
The client confirms the Trust, trustee, ABN and controlling people in InvestorKit Engage.
Record the purchase-structure revision, complete the amended agreement process and reopen the Engage AML step.
Compliance must confirm that the correct AML Partners entity parties and fresh check were created. Do not assume the reopened step did this. A further provider fee may apply.
Tell the client this may delay exchange.
Send the selling agent only the updated legal Buyer and contract details. Never send AML evidence.
Q: Does the client pay InvestorKit again when they sign the amended agreement?
Not if the InvestorKit agreement fee was already paid.
If it was unpaid, InvestorKit Engage should still show the unpaid balance.
A card payment attempt or reported bank transfer is not confirmed payment.
Any new AML Partners fee is separate from InvestorKit's fee.
Q: The offer was submitted, but it has not been accepted yet. The client changes the Buyer. What now?
Stop and tell the selling agent the offer needs correction.
Ask the client's solicitor or conveyancer how to change or replace it.
Complete the amended InvestorKit agreement and obtain Compliance confirmation that the provider check is correctly scoped.
Do not continue until the offer, agreement, provider parties and cleared Buyer all match.
🎉 Offer Accepted
Every Seller check starts and stays in InvestorKit Engage
Open the property-linked Seller workflow first. Record the chosen route, contact attempts, approved evidence, AML Partners status and final Compliance decision there. Evidence from an agent, solicitor or vendor still belongs in this Engage workflow.
Same agreement, different views
Staff see the owner, due action and Seller checklist. Customers see a plain-language Seller status only. They never see staff notes, provider evidence, screening or Compliance reasoning.
Staff view: the Offer Accepted workspace makes the Seller task, owner and due action explicit.
Customer view: a safe Seller status with no staff-only or identity evidence.
flowchart TD
A[Offer Accepted] --> B[Open Seller workflow in Engage]
B --> C[Confirm five deal facts]
C --> D{Choose one Engage route}
D -->|Consented natural-person Seller| E[Direct AML Partners invitation if enabled]
D -->|Approved third-party evidence| F[Secure evidence upload]
D -->|No access or refusal| G[Record reasonable steps]
E --> H[Compliance decides]
F --> H
G --> HOwner | Responsibility |
SSC | Owns the property-linked Seller workflow, outreach record and deadline follow-up in Engage. |
Acquisitions or agreement owner | Confirms the accepted Buyer, structure and contract handover. |
AML Partners | Performs secure provider checks when Engage sends an approved direct route. |
InvestorKit Compliance | Selects the lawful route, reviews evidence and records the final decision. |
What Engage records and controls
- Staff-only Seller checklist, property link, evidence ledger, no-contact record and linked provider status.
- Five mandatory preparation confirmations before a route is submitted.
- Direct invitation only when the one-deal AML Partners route is enabled; natural-person Sellers only, with consent and verified contact details, up to six people.
- Evidence upload and no-contact records as inputs to Compliance, never automatic clearance.
- Advisory deadline display. Engage does not technically block exchange or settlement.
- Staff interactions. Engage does not contact the selling agent, solicitor, conveyancer or vendor automatically.
Staff view: Seller preparation remains locked until the linked Seller compliance record exists. These confirmations prepare the check; they do not clear the Seller.
Before choosing a route
Choose one Engage route
Route A: consented direct invitation — InvestorKit's own outsourced CDD
- Confirm this is a natural-person Seller who agreed to receive AML Partners contact.
- Confirm the email or mobile belongs to that Seller.
- Enter the exact legal name and verified contact in Engage.
- Use Invite Seller securely only if that Engage control is available.
- Confirm the returned record covers the required identity fields, verification source and result, identity match, PEP and sanctions screening, alerts and audit trail.
- Add the property and transaction link, representative or authority information, InvestorKit's own Seller risk assessment, any enhanced CDD and the final Compliance decision.
AML Partners is an outsourced provider. Its green result is evidence, not InvestorKit's legal decision, and InvestorKit remains responsible. Never send a personal verification link to an agent or representative to complete as though they were the Seller.
Route B: approved third-party evidence or a documented legal arrangement
- Ask the selling agency, solicitor or conveyancer exactly what KYC it collected, what it verified and what underlying reliable and independent data it can provide securely.
- Confirm the person or business performed relevant AML/CTF CDD as an eligible reporting entity or eligible foreign equivalent—not merely a state identity or right-to-deal check.
- Confirm the report names the same legal Seller, capacity and property as the contract and resolves any discrepancy.
- Upload it through the restricted Engage evidence action and record the legal route proposed: Rule 6-33(1), an ongoing reliance arrangement under section 37A and Rule 6-29, or case-by-case reliance under section 38 and Rule 6-31.
- Confirm the KYC and verification data can be obtained within the applicable deadline. Under ordinary reliance, AUSTRAC generally does not expect verification-data delays beyond one business day after request.
- Treat a report, certificate or VOI result as supporting evidence only unless Compliance accepts the relevant arrangement or reliance and records InvestorKit's remaining CDD and risk decision.
Route C: no access, refusal or silence
- Ask for Seller consent, direct contact or an introduction.
- Offer a neutral request the agent can forward.
- Try the Seller solicitor or conveyancer, including through the Buyer conveyancer.
- Offer a secure evidence or documented information-sharing route.
- Use Request Compliance review in Engage and record every date, channel, request, response and outstanding item.
- Identify who blocked access: agent, solicitor, Seller or missing details.
- Compliance sees the review in the AML hub automatically. Do not mark the Seller cleared.
Evidence bar — what a sufficient Seller file usually contains
- Ordinary low-risk individual Seller: full legal name; other or former names where relevant; date of birth; residential address; any useful unique identifier; the reliable and independent source, method, date and result used to verify identity; reasonable steps showing the individual is who they claim to be; PEP and targeted-financial-sanctions results; transaction and property link; any representative and authority; discrepancies and resolution; InvestorKit's own risk rating and final decision.
- Joint Sellers: address every legal Seller separately. One spouse, co-owner or representative does not automatically complete the others.
- Company, Trust, SMSF or other non-individual Seller: add the entity's legal identity and existence, structure, trustees or directors, representatives and authority, ownership and control chain, beneficial owners or other controlling individuals, and risk-appropriate verification and screening. Verifying only the person who speaks to the agents is not enough.
- Source of funds or source of wealth: not a universal request for every ordinary low-risk Seller. Obtain it where enhanced CDD, a PEP rule, high risk, unexplained wealth, unusual complexity, inconsistency or another trigger makes it necessary.
- Supporting but not complete by itself: contract, title search, PEXA or conveyancing VOI certificate, identity summary, CDD report or offshore report. Each may cover only part of the obligation.
- Not enough by itself: a one-line verified, passed or cleared email; a screenshot or platform green tick with no underlying data; a mismatched report; an incomplete invitation; or an unsupported assertion that another professional checked the Seller.
- InvestorKit always retains: the matters not legally deemed complete, its own ML/TF risk identification, any additional risk-appropriate KYC, enhanced CDD where required, monitoring, reporting decisions and records.
Timing
Finish as soon as possible. InvestorKit aims to complete the work within 15 days after exchange, or earlier if settlement requires it. The legal outside deadline is the earlier of 28 days after exchange or 3 days before the initially agreed settlement date. Escalate an auction, short settlement or missing date immediately.
Questions: clearance and Seller access
Q: Does Offer Accepted mean the Seller is cleared?
No. It starts the Seller workflow. A record, invitation, upload or refusal note is not clearance.
Q: The selling agent will forward our request but will not disclose Seller contact details. What do we do?
Accept the forwarding route.
Send a neutral request asking the Seller to consent to an AML Partners invitation initiated through Engage, contact InvestorKit, or authorise its solicitor or agent to provide approved evidence.
Record what was forwarded, by whom and when. Do not record it as Seller refusal unless the Seller personally refuses.
Q: The selling agent says, “We do the AML and will never pass on Seller details.” What do I do?
Short answer
Stay calm. Do not argue.
The selling agent may be protecting the Seller's privacy. That is reasonable. But its check does not automatically complete InvestorKit's separate duty as the buyer's agent.
This message proves agent refusal only. It does not prove that the Seller personally refused a secure check.
What this means for InvestorKit
- Open the property-linked Seller checklist in InvestorKit Engage.
- Save the email and record Selling agency declined to assist. Do not select Seller refused unless the Seller personally declined.
- Do not ask for passports, licences, selfies or other raw ID by normal email.
- Offer three safe routes:
- The agent forwards InvestorKit's neutral request asking the Seller to contact us or consent to direct AML Partners verification. Do not send a Seller verification link through the agent unless Engage and Compliance approve that route.
- With the Seller's consent, AML Partners contacts the Seller directly.
- The agencies or the Seller's conveyancer use a documented AUSTRAC verification or reliance process and a secure transfer.
- If all routes fail, record every request, response and difficulty on the Seller check, then choose Request Compliance review in Engage.
- Compliance decides whether more steps are needed, whether the actual Seller—not merely an intermediary—has failed to cooperate so that Rule 6-33(3) may apply, and whether an SMR obligation must be considered and recorded.
- Never tell the agent that an SMR is being considered or submitted.
A refusal does not automatically make the Seller suspicious and does not automatically stop the transaction.
Is one request enough?
No fixed number of requests appears in the Rule. One email is not an automatic safe harbour.
InvestorKit must take all reasonable steps available for that deal. What is reasonable depends on the risk, the information already available and which people can be contacted.
A sensible minimum file usually shows:
- The contract was checked for the exact Seller name, legal capacity, property, exchange date, initially agreed settlement date and conveyancer or solicitor.
- The title or another reliable source was checked where available.
- A clear written request was sent without asking for raw ID by email.
- The agent was offered a neutral AML Partners invitation to forward.
- The agent was asked whether the refusal came from the agency or the Seller personally.
- The agency's AML/CTF compliance officer, the Seller's conveyancer or another secure verification route was offered where available.
- Any independent identity, entity, PEP or sanctions checks requested by Compliance were completed through approved tools.
- Every step, response and difficulty was recorded.
- Compliance recorded its decision and its private consideration of any SMR obligation.
A single exchange may be enough only where it clearly closes every genuinely available route and Compliance agrees. Staff must not make that decision themselves.
What can a contract-of-sale cross-check prove?
It can support the Seller's legal name, capacity, property, transaction purpose, representatives and key dates. A title search can support who is recorded as the owner.
A contract alone does not usually verify an individual's identity. It may also omit beneficial owners, representative authority, PEP or sanctions checks, or details of a Trust or Company structure.
Use it as part of the reasonable-steps evidence. Do not turn Contract checked into Seller cleared.
If normal verification cannot be completed because the Seller genuinely does not cooperate, Compliance may use the Rule 6-33 pathway after all reasonable steps and records are complete.
When this duty starts
For InvestorKit as the buyer's agent, the Seller normally becomes part of our AML process once the transaction is reasonably expected to proceed. AUSTRAC says this is typically after the offer is accepted and the contract is signed.
If the matter is only at Submitted Offer, prepare the Seller workflow but do not collect unnecessary personal information early.
If delayed CDD is lawfully used, complete it as soon as possible and no later than the earlier of 28 days after exchange or 3 days before the initially agreed settlement date.
Use the live templates in InvestorKit Engage
Do not copy old replies from this FAQ. Open AML guides and replies, choose the situation and replace the bracketed fields. Save the reply or refusal on the linked Seller check.
Every live reply includes the public Seller verification guide and current official sources.
Guidance version: 2026.07.20.
Q: The Seller personally refuses or stops responding. What now?
Record the actual Seller refusal or silence and every reasonable step taken, including secure direct verification, a neutral request forwarded by the selling agency, an introduction, and eligible third-party or reliance routes where reasonably available.
For InvestorKit as the Buyer's agent, the relevant provision is Rule 6-33(3). It applies only where the actual Seller has not cooperated, InvestorKit has taken all reasonable steps, and InvestorKit records the steps, difficulties and its consideration of any SMR obligation.
A selling agent, solicitor or conveyancer refusing to transmit information is an access blocker; it is not automatically proof that the Seller personally refused.
Non-cooperation is not automatic clearance, suspicion or an automatic report. Compliance makes and records the decision.
Q: The solicitor or conveyancer refuses on privacy grounds. What do we do?
Ask what authority or Seller instruction it needs and offer a secure route that lets the Seller complete InvestorKit's check directly without identity documents moving through ordinary email.
Ask whether the firm is an AML/CTF reporting entity for the relevant service and whether it completed AML CDD, rather than only a state VOI, PEXA or right-to-deal check. If so, ask whether it can provide specified KYC and verification data under a documented Rule 6-33 or ordinary reliance route.
A solicitor or conveyancer's professional status or licence does not by itself make its certificate complete AML CDD evidence. Record its refusal as a solicitor or conveyancer access blocker, not automatically as Seller refusal.
Questions: unusual Sellers and transaction structures
Q: We have a company, Trust, SMSF, deceased estate, mortgagee, receiver, government or foreign Seller. What do we do?
Record the exact legal Seller and capacity, the entity's identifying information and existence, every representative, and reliable evidence of each representative's authority.
For a company, trace ownership or control to the relevant individuals and identify beneficial owners. For a Trust or SMSF, establish the Trust, trustees, any corporate trustee, controllers and other persons required by the applicable customer-type procedure. For an estate or attorney sale, establish the executor, administrator or attorney and the grant or authority relied upon.
A contract name, ASIC extract, Trust deed or probate document can be important evidence, but no single document automatically completes identity, control, representatives, PEP or sanctions, risk and verification requirements.
The current Engage direct Seller route models natural people only. It does not provide a complete electronic Seller KYB path for these cases. Stop and ask Compliance to set the customer type, ownership, authority, screening and verification route before treating any evidence as sufficient.
Q: There are multiple Sellers. Does one completed person cover them all?
No. Treat each joint Seller separately and match every legal name and capacity.
The current direct route accepts up to six natural-person Sellers. More than six, a mixed entity/person group, or a disputed Seller requires Compliance.
Q: It is an auction or short settlement. Can CDD simply wait?
No. Delayed CDD is permitted only in limited circumstances where delay is essential to ordinary business and the added risk is low.
Start immediately after the transaction becomes likely to proceed and escalate the timing to Compliance. Inconvenience alone is not enough.
Q: The legal Seller changes after the workflow started. Does the old evidence transfer?
No. Stop and confirm the new contract, legal Seller, capacity and representative authority.
The current app does not automatically remove old Sellers or reset all check-scoped evidence. Compliance must reopen or rebuild the correct scope.
Questions: evidence, privacy and outages
Q: Can staff upload raw Seller ID into InvestorKit Engage?
Only through a Compliance-approved secure method into restricted storage.
Never ask for or accept raw ID through ordinary email, WhatsApp, SMS or personal email. Prefer direct secure collection.
Q: What if raw ID arrives by ordinary email or WhatsApp?
Do not forward, duplicate or place it in general Attio notes.
Email compliance@investorkit.com.au with Privacy incident in the subject and follow the containment steps.
Q: Can another party's report or VOI certificate clear the Seller for us?
Not automatically. A VOI or right-to-deal check may support identity and authority but may not cover beneficial ownership, control, representatives, PEP and sanctions, nature and purpose, InvestorKit's risk assessment or enhanced CDD.
A report is supporting evidence until Compliance confirms what it actually covers, whether the provider is eligible for the proposed legal route, access to the KYC and underlying verification data, privacy authority, discrepancies, and any required written arrangement or case-by-case reliance record.
A certificate or Seller verified statement alone does not transfer accountability to the issuer.
Q: AML Partners or Engage is unavailable. What do we do?
Record the outage, deadline and safe steps already taken. Approved evidence and no-contact notes may still be recorded when available.
Do not call the Seller cleared and do not create a duplicate provider case. Escalate to Compliance.
Questions: using Engage
Q: What should the SSC click in InvestorKit Engage?
Open the property-linked Seller checklist and complete the five confirmations. Then choose the route actually available in Engage: Invite Seller securely, Upload secure evidence or Request Compliance review.
Uploading third-party evidence or recording no-contact steps opens a visible review inside Engage. Email is not the handover.
Do not mark the Seller cleared.
Q: What is live today?
The staff checklist, secure evidence upload, no-contact/refusal review, provider status, deadlines, reply library and public guide are part of InvestorKit Engage.
External outreach remains manual. Use Invite Seller securely only when Engage shows it. When the one-deal path is enabled, Engage adds Sellers to the existing Buyer deal. An older separate Seller case may only be continued. Staff must not create a separate Seller case.
Entity/trust Seller KYB, auction-specific logic, changed-Seller reset and a hard settlement gate are not automated.
If the property-linked check is missing, use the AML hub to confirm it. Use the emergency email path only because there is no safe record to attach the issue to.
📨 Selling-agent handovers, privacy and secure sharing
Start from Engage, even when another agency is involved
Open the linked Buyer or Seller workflow before responding. Record routine Buyer facts, Seller contact attempts, third-party evidence, privacy decisions and any reliance proposal there. Engage connects the work to AML Partners. InvestorKit Compliance makes the decision.
Staff view: Buyer Handover is a separate, limited factual pack. Engage blocks it when authority, contact, capacity or property facts are incomplete, and gives staff the approved reply boundary.
flowchart TD
A[Open linked Engage record] --> B{What is needed?}
B -->|Routine contract facts| C[Verified work channel]
B -->|Identity verification| D[Secure customer process or AML Partners via Engage]
B -->|Seller evidence| E[Restricted Engage Seller record]
B -->|Reliance, risk or reporting| F[Compliance only]Stage rule
- Owner: the sender owns the disclosure; the SSC owns Seller evidence and access steps.
- Through Engage: confirm the current party, property, purpose and linked check before sending or receiving anything.
- Complete when: the verified recipient receives only the minimum authorised information and the action is recorded against the right workflow.
- Stop when: purpose, permission, recipient, channel, raw ID, reliance or risk information is unclear.
Before sharing or receiving information
Never trade or casually forward AML files
Buyer information-sharing and Seller access are separate obligations. A missing Seller contact does not give another agency access to InvestorKit’s Buyer AML file. Rule 6-33 and ordinary reliance require Compliance review. An email request or customer form creates neither.
Questions: roles and stage handover
Q: What does the stage mean for a selling agent versus a buyer's agent?
Role | Who they act for | Customer checked before their service starts | Check of the other side when the sale is likely to go ahead |
External selling agent | The seller | The seller, normally when the selling-agency agreement begins | The buyer, typically when the offer is accepted and the contract is signed |
InvestorKit as buyer's agent | The buyer | The Buyer before the designated brokering service starts. AUSTRAC says this generally occurs when the agreement to find or identify property is signed. | The Seller when the transaction is reasonably expected to proceed, typically when the offer is accepted and the contract is signed. |
The selling agent and InvestorKit each check the customers required for their own brokering service, and each makes its own decision.
The Attio stage is an operational indicator, not the legal test. Follow the actual facts: the counterparty trigger is when it is reasonably expected that the transaction will proceed, which AUSTRAC says is typically when the offer is accepted and the contract is signed.
Q: What may move between the agents while Searching or Presenting?
Send property questions, viewing requests and approved facts needed to discuss the property.
Receive listing, contract, vendor, inspection and property documents.
Never send ID, birth date, AML status, financial evidence or internal notes.
Q: What may InvestorKit send when submitting an offer?
Send exact purchaser names, capacity, entity wording, price, deposit, conditions, settlement request, expiry and approved contact.
Use verified InvestorKit work email.
Q: What may move after Offer Accepted and during contract preparation?
InvestorKit sends the approved minimum Buyer, entity, contact and transaction facts needed for the contract and to begin the selling agent's check.
The selling agent sends its privacy notice and secure customer process, and may send contracts, vendor documents, Seller names, contacts and dates.
The purchaser or authorised officer confirms declarations and provides sensitive evidence through that secure process.
Raw ID never goes in normal email.
Questions: responsibilities when InvestorKit represents the Buyer
Q: Who owns what when InvestorKit represents the Buyer?
Party | Owns | What it must do |
InvestorKit Compliance | InvestorKit's Buyer CDD and separate Seller counterparty CDD | Confirm our Buyer evidence matches the current legal purchaser and structure, record our decision, retain our evidence, and continue the Seller check |
Settlement Support Coordinator or agreement owner | Purchaser liaison and factual handover | Confirm the current legal purchaser and provide the approved minimum purchaser, entity, contact and transaction facts; arrange secure completion by the purchaser or authorised officer; do not sign, certify or disclose InvestorKit's internal AML evidence |
External selling agent | Its own CDD on the Buyer | Issue its privacy notice and secure request, decide what it needs, collect and verify the information, assess risk, record its decision and retain its evidence |
Purchaser or authorised entity representative | Its answers and declarations | Answer any declarations the selling agent requires under its risk-based process and provide sensitive evidence directly through its secure process |
Each agency owns its own decision. Neither agency's file automatically completes the other's obligation.
Q: We already hold the purchaser's CDD evidence. What must InvestorKit Compliance do?
- Confirm the evidence matches the current legal purchaser, purchasing capacity and structure in the offer or contract.
- Confirm the required people and entities, representative authority, beneficial ownership, screening, risk assessment and any required enhanced CDD are complete.
- Record InvestorKit's own final Buyer CDD decision and retain the evidence.
- Continue InvestorKit's separate CDD on the Seller as the transaction counterparty.
- Decide any written request for agency or formal reliance. Unless Compliance approves it, do not transfer InvestorKit's AML file.
If steps 1 to 3 are complete, the selling agent's form creates no additional Buyer CDD decision for InvestorKit. Staff still represent the purchaser and provide the approved minimum factual details needed for the transaction.
Q: What must the selling agent do?
The selling agent owns its own CDD on the purchaser.
It decides what KYC information and evidence it needs under its AML/CTF program. It gives the purchaser its privacy notice and secure process, verifies the information, assesses risk, records its decision and keeps its evidence.
The contract gives it starting information, not a completed CDD file.
It may ask InvestorKit to facilitate contact, but it cannot treat InvestorKit's work as completing its own obligation unless a valid legal mechanism is used. That may be an approved written ongoing reliance arrangement, documented case-by-case reliance, or a compliant Rule 6-33 same-transaction arrangement. Each route has separate eligibility, risk, data-access and record requirements.
Questions: selling-agent purchaser forms and factual handover
Q: A selling agent asks us to complete its CDD form for our purchaser. What do we do?
Do not complete declarations or sign the selling agent's CDD form for the purchaser. InvestorKit represents the purchaser, so staff should provide only the minimum factual purchaser and transaction details we hold and are authorised to disclose.
First open the signed contract or accepted offer. Compare it with the linked Engage agreement and Buyer status by hand. Engage does not hold every contract field or perform this comparison.
Provide the approved facts in a separate confirmation, or complete factual fields only. Make clear that the selling agent must confirm and verify the information under its own AML/CTF program.
Ask the selling agent for its privacy collection notice and secure completion or upload method.
Any declarations, beneficial-ownership or PEP questions, risk-based funding questions, sensitive evidence and any required signature must come from the purchaser or a genuinely authorised officer through the selling agent's secure process.
InvestorKit staff must not complete or sign those parts for them.
Q: What information may InvestorKit give the selling agent about our purchaser?
Provide only facts we actually hold, have checked and are authorised to disclose.
Start with staff-visible Engage and Attio facts:
- primary purchaser name and approved contact details;
- Purchase Type: individual, joint, Company, Trust or SMSF;
- entity or trust name;
- linked property address, price and current exchange or settlement date, where populated.
Do not disclose InvestorKit's Buyer-check status under an ordinary customer-form request. Any statement about InvestorKit's own CDD requires Compliance-approved wording and a check of that specific agreement.
Check the signed contract, accepted offer or purchaser directly for facts not reliably visible in Engage:
- exact purchasing capacity and trust wording;
- ABN or ACN;
- authorised officer or representative and their authority;
- deposit, conditions and the initially agreed settlement date;
- solicitor or conveyancer details; and
- entity registered or principal address.
Do not promise that these second-list facts are available in Engage. Prefer the purchaser or authorised officer giving them directly through the selling agent's secure process.
Label it as factual transaction information provided for the selling agent to confirm and verify. Do not certify it.
If the selling agent genuinely needs a date of birth, residential address or beneficial-owner personal information, confirm the authority and use the selling agent's secure process. The purchaser or authorised officer should provide it directly.
Do not send identity-document images, selfies, AML Partners outputs, AML status, screening results, risk ratings, internal notes, or source-of-funds or source-of-wealth evidence unless Compliance has approved the legal basis, scope and secure transfer.
Questions: AML Partners, reliance and Rule 6-33
Q: What exactly is the difference between an ordinary form, AML Partners, reliance and Rule 6-33?
Mechanism | What it means | What it does not mean |
Selling agent customer form | The selling agent collects and verifies its own customer information. InvestorKit may provide approved minimum factual fields; the customer or a genuinely authorised representative completes any declarations and sensitive evidence required by that form. | No reliance or shared-CDD arrangement exists. AML/CTF law does not universally require every customer form, privacy consent or signature. |
AML Partners | An outsourced provider performs secure collection and checks for InvestorKit. | InvestorKit remains legally responsible. AML Partners is not automatically a reporting entity on which the selling agent can rely. |
Ordinary reliance | Sections 37A or 38 and Rules 6-29 or 6-31 may deem specified KYC collection and verification complete when eligibility, risk, documentation and data-access conditions are met. | It does not transfer InvestorKit's remaining duties or recordkeeping, and a certificate alone is insufficient. |
Rule 6-33(1) | A special same-transaction arrangement with another participating reporting entity. If its conditions are met, only the specified section 28(2)(b), (d), (e) and (g) matters are deemed established. | It is not blanket CDD or a transfer of accountability. InvestorKit still takes reasonable steps on an individual Seller's identity, identifies its own ML/TF risk, collects risk-appropriate KYC and completes remaining duties. |
Rule 6-33(2) or (3) | A recorded pathway where the actual counterparty customer does not cooperate. Rule 6-33(3) is the provision relevant to InvestorKit as the Buyer's agent dealing with a non-cooperative Seller. | It requires all reasonable steps, records of those steps and difficulties, and recorded consideration of any SMR obligation. Intermediary refusal alone is not automatically customer non-cooperation, suspicion or an AUSTRAC report. |
Q: Can we tell the selling agent that InvestorKit completed its own purchaser CDD?
Only after checking that specific agreement and using Compliance-approved wording. Do not call it enhanced CDD unless enhanced CDD was actually required and completed.
Do not issue a passed, cleared or CDD certificate that implies the selling agent may adopt our decision.
There are two different formal routes:
- Ordinary reliance on previously completed KYC: the selling agency's Compliance team must assess sections 37A or 38 of the AML/CTF Act and Rules 6-29 to 6-31.
- Rule 6-33 same-transaction arrangement: if the selling agency wants InvestorKit to act as the other participating reporting entity that collects and verifies specified KYC for the same transaction, InvestorKit policy requires the current AUSTRAC starter-kit form with Parts 1 to 3 completed and Part 3 signed. No arrangement exists unless InvestorKit Compliance approves, completes and signs Part 4.
The AUSTRAC form is a starter-kit template, not a legally required form. AUSTRAC's Release 1.1, dated 3 June 2026, updated the real-estate starter-kit documents from the former 15-day wording to the current 28-day and 3-days-before-settlement framework. Do not use an old copy that still says 15 days.
Keep the two legal clocks distinct. Under Rule 6-32, delayed counterparty CDD must be completed by the earlier of 28 days after exchange or 3 days before the initially agreed settlement date. Under a Rule 6-33(1) arrangement, the other reporting entity must be able to collect and verify the specified KYC no later than 28 days after exchange, and the arrangement must enable InvestorKit to obtain the KYC and copies of the verification data at least 3 days before the initially agreed settlement date.
Neither route gives blanket permission to share personal information. Confirm the original collection purpose and notice, a lawful basis, need, accuracy and secure delivery. Consent does not make an excessive or insecure disclosure acceptable.
Q: Does an AUSTRAC entity onboarding form mean every listed document is required?
No.
First confirm the form matches the purchaser type. A Company, partnership or unincorporated association uses different requirements from an individual, Trust or SMSF.
This form says one or more entity documents may be used. It does not require every Appendix A item. Source-of-funds or source-of-wealth evidence is optional on the form, not a universal requirement for every low-risk customer.
A representative may act only when they have real authority, such as written customer authority, an agency agreement or power of attorney. The person signing confirms accuracy and consent. An InvestorKit job title alone is not authority.
Ask the selling agent to identify the minimum evidence required under its risk-based process. The purchaser or genuinely authorised representative should upload sensitive evidence directly through the selling agent's secure process.
Questions: Seller access, refusals and approved scripts
Q: The selling agent will not give us the Seller's contact details. Does that change what we provide about the Buyer?
No. These are separate obligations, not a trade.
Continue to provide the approved minimum Buyer and transaction facts under the rules above and direct declarations and sensitive evidence through the selling agent's secure customer process.
Separately record agent refusal. Ask the agent to forward our neutral Seller contact request or arrange an introduction. Try the Seller's solicitor or conveyancer, then escalate InvestorKit's Seller check to Compliance.
Q: What should Compliance tell staff handling a selling-agent purchaser CDD request?
Say:
InvestorKit represents the purchaser. Compare the signed contract or accepted offer with the linked Engage agreement and Buyer status. Then provide only the minimum authorised facts for the current purchaser and transaction.
Make clear that the information remains for the selling agent to confirm and verify under its own AML/CTF program. Ask it to send its privacy notice and secure process directly to the purchaser or genuinely authorised representative for anything its form requires them to declare, evidence or sign.
Do not sign, execute, certify or attest the selling agent's form for the purchaser unless InvestorKit holds specific authority for that act and Compliance approves it. Do not provide InvestorKit's AML Partners file, provider outputs, screening, risk assessment or financial evidence under an ordinary customer-form request.
Keep the formal routes separate. Reliance on InvestorKit's previously completed KYC is assessed under sections 37A or 38 and Rules 6-29 to 6-31. If the selling agency instead asks InvestorKit to act as the other participating reporting entity that collects and verifies specified KYC under Rule 6-33, InvestorKit policy requires Parts 1 to 3 of the current AUSTRAC starter-kit form completed and Part 3 signed. InvestorKit is not bound unless Compliance approves, completes and signs Part 4.
Any missing Seller contact remains a separate InvestorKit Seller-check issue and does not change the approved Buyer information we provide.
Q: What approved response can I send to the selling agent?
Say:
InvestorKit represents the purchaser and can provide authorised factual purchaser, entity, contact and transaction details for this transaction. Your agency remains responsible for confirming and verifying them under its own AML/CTF program.
Please send your privacy notice and secure form or upload link directly to the purchaser or genuinely authorised representative for anything they must declare, evidence or sign. InvestorKit cannot sign or attest your form for the purchaser or provide internal AML Partners evidence under an ordinary onboarding request.
If your agency wants to rely on InvestorKit's previously completed KYC, please have your Compliance team identify the proposed reliance basis under sections 37A or 38 of the AML/CTF Act and Rules 6-29 to 6-31.
If your agency instead wants InvestorKit to act as the other participating reporting entity that collects and verifies specified KYC under Rule 6-33, InvestorKit policy requires Parts 1 to 3 of the current AUSTRAC Request to verify information form completed and Part 3 signed. No arrangement exists unless InvestorKit Compliance approves, completes and signs Part 4.
Q: What are the Seller-check dos?
Confirm the property-linked record, legal Sellers, contacts and dates.
Choose agent evidence, direct invitation or no-contact/refusal.
Save approved evidence and factual notes.
Track the earlier of the two legal deadline dates.
Get the final Compliance decision.
Q: What are the Seller-check don'ts?
Do not treat a record, invitation, screenshot, upload or electronic-only attempt as clearance.
Do not request ID by email, chat or WhatsApp.
Do not create duplicate cases, mix Seller and Buyer status, or reveal internal concerns.
Q: Can InvestorKit use the selling agent's Seller check instead of starting again?
Potentially, but never automatically and not merely because the agent says it completed AML.
Compliance must first identify the legal mechanism: a Rule 6-33(1) same-transaction arrangement, an ongoing reliance arrangement under section 37A and Rule 6-29, or case-by-case reliance under section 38 and Rule 6-31. The mechanisms have different scope and conditions.
For Rule 6-33(1), responsibilities including records must be documented; the other participating reporting entity must be able to collect and verify the specified KYC by the Rule's timing; and InvestorKit must be able to obtain the relevant KYC and copies of the verification data at least 3 days before the initially agreed settlement date. Only specified section 28(2) matters are deemed established.
For ordinary reliance, the relied-on party must be eligible, reliance must be appropriate to InvestorKit's risks, the required KYC must be obtainable within the applicable timeframe, and the underlying independent verification data must be available immediately or as soon as practicable after request.
InvestorKit still owns its own risk identification, any non-deemed or non-relied-on CDD, additional risk-appropriate KYC, enhanced CDD, monitoring, reporting decisions and records. A certificate, screenshot, platform badge or Seller verified email alone is not enough.
Q: Do we report a selling agent who will not cooperate?
No automatic report is made.
Record the refusal, try the neutral-forward, solicitor and secure-evidence routes, and send the facts privately to Compliance.
Compliance considers the actual customer's cooperation, all other risk factors and any SMR obligation. Never threaten reporting or reveal a suspicion.
Q: The selling agent offers Seller evidence only if we give it our Buyer AML file. What do we say?
Say: “The Buyer and Seller checks are separate obligations, not an evidence trade. We can provide the approved minimum purchaser and transaction facts. Any sensitive CDD exchange requires purchaser authority, a secure channel and a Compliance-approved arrangement.”
Continue the Buyer handover and Seller access steps separately.
Questions: privacy, evidence storage and secure channels
Q: How must each type of information be shared?
Information | Approved method | Do not use |
Routine offer and contract details | Approved template from an InvestorKit work account to a verified named recipient; minimum necessary details only | Personal email, WhatsApp, SMS, broad mailing lists or unnecessary CC recipients |
Contracts, title or vendor documents | Approved transaction portal or secure link where available; otherwise verified work email for ordinary transaction documents, then restricted internal storage against the agreement or property | Public links, InvestorKit EDGE (Client Portal) as an AML store, unrestricted shared drives or forwarding to unrelated staff |
Identity documents and verification steps | For InvestorKit's check, AML Partners' direct secure invitation. For another agency's check, that agency's secure customer process. Formal evidence sharing requires a Compliance-approved arrangement. | Email attachments, chat, SMS, WhatsApp, Attio general notes, InvestorKit Engage client notes or InvestorKit EDGE (Client Portal) |
Seller CDD or reliance evidence | Compliance-approved secure transfer and the restricted property-linked Seller compliance check | Normal deal email threads, screenshots, shared inboxes or broad staff access |
Internal status, owner and next action | InvestorKit Engage AML hub or Attio compliance check; send staff a link to the record | Copying sensitive details into email, chat or InvestorKit EDGE (Client Portal) |
Concerns, screening or reporting decisions | Restricted Compliance channel only | Any client, Seller, selling-agent or general staff communication |
Q: What privacy check must staff complete before sending anything externally?
Before sending, check the purpose, privacy notice under APP 5, authority or consent, minimum information, verified recipient, secure channel and internal record.
Rule 6-33 or a reliance proposal does not by itself authorise broad disclosure under privacy law.
If one element is unclear, do not send. Email compliance@investorkit.com.au.
Q: What if sensitive information arrives by normal email or is sent to the wrong person?
Do not forward or copy it.
Email Compliance with Privacy incident in the subject.
State what, who, when and whether it was opened.
Follow their instructions.
Q: What can we say when we cannot share information?
Say: “We can send the contract details needed for this deal. Identity information must use the secure process. Tell us exactly what your office needs.”
🏠 Exchanged → Settled
Complete the Seller check through Engage before the applicable deadline
- Owner: SSC; Compliance owns the final decision.
- Through Engage: track the linked Seller workflow, evidence, provider status, exchange date and Seller deadline.
- Complete when: required Seller CDD and unresolved risk are dealt with before the deadline.
- Stop when: dates disagree, the initial settlement date is unknown, a Seller changed, evidence is incomplete or the decision is unresolved.
System limit: Engage can calculate a comparison date from current property data. It does not preserve a separate, provable initially agreed settlement date. The display is guidance only and does not block settlement.
Do not mix the Rule 6-32 and Rule 6-33 clocks
- Rule 6-32 delayed Seller CDD: complete by the earlier of 28 days after exchange or 3 days before the initially agreed settlement date.
- Rule 6-33(1) same-transaction arrangement: the other participating reporting entity must be able to collect and verify the specified KYC no later than 28 days after exchange, and InvestorKit must be able to obtain the KYC and copies of verification data at least 3 days before the initially agreed settlement date.
- Both are outside controls, not targets. Start when the transaction is reasonably expected to proceed and finish as soon as reasonably practicable.
Exchanged: staff and customer views
Staff see the deadline follow-up and Seller work. Customers see the transaction stage and a safe status only.
Staff view: Exchange changes the action and deadline prompt.
Customer view: settlement guidance and a customer-safe Seller status.
flowchart LR
A[Exchange and settlement facts] --> B[SSC checks outside deadline]
B --> C[Complete Seller CDD as soon as possible]
C --> D{Decision complete?}
D -->|No| E[Escalate]
D -->|Yes| F[Retain evidence]Checklist
Common questions
Q: What is left after exchange?
Finish the Seller check as soon as possible.
Do not treat 28 days as the target. The requirement to finish 3 days before settlement, or InvestorKit's earlier target, may come first.
Q: What if settlement is less than a week away?
Escalate now. The 3-day deadline may already be close or passed.
Do not assume a short settlement creates an exemption or that Engage will block settlement.
Q: Settlement was extended. Does the legal deadline move?
Do not recalculate from the extended date without Compliance review.
The Rule uses the initially agreed settlement date. Engage may display a date derived from the current property record, so preserve the original contract date and escalate any mismatch.
Q: The Buyer asks to change the purchasing entity after exchange. Can I update Attio and continue?
No. Stop and contact Compliance and the Buyer's solicitor or conveyancer.
The legal documents, InvestorKit agreement, Buyer CDD and counterparty scope may all need reassessment.
Q: The deal is rescinded, cancelled or does not settle. Can we delete the Seller material?
No. Update the deal status through the approved process and tell Compliance.
Compliance decides whether the work closes and which records must be retained.
Q: What happens after settlement?
Record the outcome and retain required AML records, usually for 7 years after the relationship or one-off transaction ends.
Do not delete or move restricted evidence yourself.
🔁 Returning Clients and Unusual Situations
A previous check is not automatically the current check
- Owner: the current agreement owner; Compliance owns reuse or re-check decisions.
- Through Engage: record the revision and open the linked check.
- Staff must check: names, entity, owners, controllers, representatives and current instructions.
- Complete when: Compliance confirms reuse or a correctly scoped new decision.
- Stop when: identity, ownership, authority, funding or behaviour raises a question.
flowchart LR
A[Client returns or facts change] --> B[Staff compare live facts]
B --> C{Old check still matches?}
C -->|Yes| D[Compliance confirms reuse]
C -->|No or unsure| E[Record revision in Engage]
E --> F[Provider update or new check]
F --> G[Compliance decides]Checklist
Common questions
Q: A past client returns for another purchase. Do they always need a new check?
Not always.
Compliance checks whether the old information is current and still matches.
Do not decide this yourself.
Q: A past client now wants to buy through a new Trust, Company or SMSF. Can we reuse the individual check?
No.
The legal Buyer changed.
Record the revision in InvestorKit Engage and obtain Compliance confirmation that the correct entity check was created and cleared.
Q: Something about the client or deal feels wrong. What do I do?
Record simple facts in the restricted channel.
Do not investigate publicly or warn the client.
Q: The seller refuses to verify. Is that automatically suspicious?
No.
A refusal is not automatic suspicion or clearance.
Record the facts and let Compliance decide.
Q: What warning signs should I escalate?
Examples include hidden owners, unexplained third parties, unusual funding, sudden entity changes, false documents, sanctions matches or pressure to avoid checks.
Escalate facts, not labels.
Q: Who decides whether to report something to AUSTRAC?
InvestorKit Compliance.
Never reveal an SMR or possible SMR.
Q: What wording can I safely use with a client?
Say check required, in progress, more information needed, under review or unable to proceed.
Do not explain internal suspicion or reporting decisions.
🧭 Problems, changes and InvestorKit Engage
Stop first; fix the linked Engage record
- Owner: the person shown on the live agreement or compliance record.
- Through Engage: confirm the agreement, payment, role, property, linked checks, owner and next action.
- Complete when: the facts are corrected and the right Compliance decision is recorded.
- Stop when: the record is missing, duplicated, inconsistent, unsecured or unresolved.
flowchart LR
A[Problem or mismatch] --> B[Stop]
B --> C[Open linked Engage record]
C --> D[Fix facts or request review in Engage]
D --> E[Continue after confirmation]Checklist
Common questions
Q: What counts as payment received?
A completed card payment counts after Stripe confirms it.
A bank transfer counts after InvestorKit reconciles the money.
A payment intent, screenshot or reported transfer is not confirmed payment.
If the original fee was already paid, an amended agreement does not charge it again.
Q: The AML check did not start. What do I do?
Check signing, payment, Buyer details and the linked Buyer record.
Do not create another AML Partners case or change No check needed.
Email compliance@investorkit.com.au with the agreement, check and property links.
Q: The check looks duplicated, expired or stuck. What do I do?
Do not delete, restart or merge it yourself.
Record the IDs and status.
Save the facts on the linked check and request Compliance review in Engage.
Q: Why can InvestorKit Engage show the AML step as complete while AML Partners is still working?
The client may have finished the Engage form.
AML Partners may still be checking identity, screening or documents.
Use the linked compliance status, not the client step alone.
Questions: deadlines, storage and privacy
Q: Who sets and owns the Seller deadline?
The SSC confirms the exchange date and the initially agreed settlement date and checks the outside deadline.
Attio's recorded Seller deadline is the primary system value; Engage may also derive a comparison from the current property dates.
Because the app does not preserve the original settlement date separately, the SSC must escalate any difference.
Q: Who may use No check needed?
Compliance only, with the legal or policy basis recorded against the decision.
The current Attio field does not technically enforce an approver or mandatory note. Staff must not select it to pass a gate or fix a workflow problem.
Q: Where can AML information be stored or shared?
Use AML Partners or another approved secure customer process for collection.
Approved Seller evidence and any provider archive stay in restricted Compliance storage linked to the check.
Internal concerns and reporting decisions stay with Compliance.
Do not retain full ID images unless Compliance confirms they are necessary. Never use general email, chat, WhatsApp, Attio general notes or InvestorKit EDGE (Client Portal).
Q: The client asks to see, correct or delete their AML information. What do I do?
Do not promise access, correction or deletion.
Record the request and email Compliance or Privacy.
Required records may need to be kept.
Questions: representatives, changes and case closure
Q: Someone else is acting for the client. What needs to be checked?
Check that person's identity and authority.
Check the legal customer and relevant owners too.
Do not treat a representative as the customer unless the documents say so.
Q: What changes can mean we need another check?
Changes to names, Purchase Type, entity, ABN, ACN, trustees, owners, controllers, representatives, funding, property or instructions can require review.
Stop and compare the new facts with the linked check.
Q: What happens if a deal is paused, cancelled, refunded or lost?
Update the commercial status through the approved process.
Do not delete AML records.
Compliance decides whether work stops, monitoring continues or records are closed.
Questions: enhanced checks and ownership handover
Q: What are source of funds, source of wealth and enhanced checks?
Source of funds means where the money used in the transaction comes from.
Source of wealth means how the person's overall wealth was accumulated.
Enhanced CDD means additional measures required by the Act, Rules and InvestorKit's risk-based AML/CTF program when a legal trigger or higher-risk circumstance applies.
They are not universal document requests for every Buyer or Seller. Compliance determines the proportionate steps for the actual trigger and risk; staff must not invent a blanket bank-statement rule or waive a legally required measure.
Q: Who owns the AML work when a deal changes hands?
The outgoing owner records the facts, status, next action and due date.
InvestorKit Engage should email the incoming owner a workspace link.
The incoming owner checks the live records before acting.
If ownership is unclear, email compliance@investorkit.com.au.
🧩 How InvestorKit Engage supports each stage
Engage is the operating gateway; AML Partners is the verification provider
Buyer and Seller checks begin from Engage, are linked to the correct agreement and property there, and return to InvestorKit Compliance for the final decision.
flowchart LR
A[Buyer or Seller facts] --> B[InvestorKit Engage gateway]
B --> C[AML Partners verification]
B --> D[InvestorKit evidence and actions]
C --> E[Compliance decision]
D --> EEngage supports
- Agreement signing, payment facts and Buyer AML submission.
- Linked AML Partners status, staff refresh and restricted provider evidence.
- Seller preparation, direct invitation when enabled, evidence upload, refusal or no-contact record and deadline display.
- Internal workflow events and Compliance escalation.
Engage does not prove or automate
- External outreach to a selling agent, solicitor, conveyancer or vendor.
- Staff comparison of current purchaser names and structure with provider parties.
- A correctly scoped provider re-check merely because the Engage AML step reopened.
- Complete entity/trust Seller KYB, auction logic, changed-Seller reset or a hard settlement stop.
- Final clearance from a form, upload, recorded attempt or provider invitation.
Common questions
Q: What does InvestorKit Engage do from signing to settlement?
It records signing and payment, supports Buyer submission, shows linked provider status and gives staff the Seller workflow when available.
Staff still confirm legal names, capacities, structures, properties, contacts, dates and evidence scope.
Q: What still needs a person?
Staff make the factual comparisons and perform external outreach.
The SSC follows the Seller routes and deadline.
Compliance approves reliance or Rule 6-33 arrangements, entity and unusual Seller routes, enhanced checks, No check needed, reporting decisions and final clearance.
📚 Sources, authority and related guidance
Use this order when instructions conflict
- Current AML/CTF law and AUSTRAC or OAIC guidance.
- A written InvestorKit Compliance direction for the specific case.
- This FAQ for the current Engage and AML Partners operating workflow.
- Older checklists and SOPs only where they do not conflict with the first three.
Current law
AUSTRAC: real estate and CDD
AUSTRAC: outsourcing, reliance and information sharing
OAIC: privacy and security
Related InvestorKit pages
Older instructions that are superseded
Use the AML Checklist’s 15-day wording as an operating target, not the legal outside deadline. Older PexaClear, legacy Attio-button, Notion evidence-log and automatic-reporting instructions in the Checklist or SOP do not override this FAQ.
Plain-English and legal-source wording reviewed: 23 July 2026.
The review corrected Buyer CDD timing, Rule 6-32 versus Rule 6-33, the limited scope of Rule 6-33(1), actual-customer non-cooperation under Rule 6-33(3), and the evidence standard for AML platforms, reliance and conveyancing VOI.
Local Engage code review remains dated 20 July 2026. Production configuration was checked only for AML_ONE_DEAL_SELLERS on that date. Live Attio records, n8n executions and AML Partners responses were not verified in this documentation review.
This remains operational guidance, not a substitute for legal advice on a specific matter. If this FAQ conflicts with a current Compliance direction or the law, stop and email compliance@investorkit.com.au.