A property listing often has one convenient contact and several legally relevant people. Joint owners, a corporate purchaser and an authorised representative can each change the CDD work. Create a party map before sending verification requests. The person answering the agent's messages is not automatically the only customer or a representative authorised to instruct for everyone named in the transaction.
Identify the service and its customer population
For the real-estate brokering service, AUSTRAC identifies both seller or transferor and buyer or transferee as customers, including the party the agent does not represent. Joint arrangements require attention to each relevant person rather than one household contact. Record legal names, capacities and which party the agency acts for. Do not import the legal adviser's customer definition into the agency file without checking the agent's own designated service.
Keep representation and ownership distinct
If one person communicates for another, identify the relationship and assess authority under the applicable CDD procedure. A spouse, adult child or employee should not simply be recorded as the owner because they handle the correspondence. For company or trust parties, distinguish the entity from its signatory and the other relevant persons. A useful file links each required matter to the appropriate person and evidence, instead of collecting several documents into an undifferentiated folder.
Work through a two-owner example
Suppose two individuals own a property and one asks a family member to coordinate the sale. Confirm who is providing instructions, for whom and under what authority. Request only the information appropriate to each role and applicable rules. If one owner is unavailable, consider the actual authority and any lawful process rather than accepting the coordinator's identity as a substitute. Property-law questions about execution or capacity may need separate professional advice.
Track completion by party and by matter
Record the request, evidence, decision and open actions for each relevant customer or representative. Keep the unrepresented-party workflow separate where specific delayed or deemed-compliance provisions may apply. Those provisions have conditions and do not automatically excuse gaps on the represented party. If the purchaser or signatory changes, update the party map and reassess the affected work. A verified household email or completed listing checklist should not conceal an unresolved person.
Official sources
Confirm the current rules against these primary sources, last checked .
Questions
Can one owner's identity check cover the other owner?
No. Establish the matters required for each relevant customer under the applicable rules. A shared address or relationship does not make them the same person.
Is the person who signs always the customer?
No. They may act for an entity or another person. Record the legal customer, representative and authority separately.
Do uncooperative-counterparty rules apply to every missing party?
No. Assess the specific provision, which party it covers and its conditions. Do not treat it as a blanket exception for an incomplete transaction file.
General information for Australian professionals, not legal advice. It does not replace the AML/CTF Act, the Rules or AUSTRAC guidance. See our editorial standards.
Keep reading
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Why Australian real estate brokers have two statutory customers, when each service starts and how to complete proportionate buyer and seller due diligence.
- Delayed CDD and non-cooperation5 min
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