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.