Overview

Customer Due Diligence (CDD) is the process of verifying a customer's identity and assessing their risk before you act for them. When you create a case for a buyer in First AML, you can carry out this verification yourself, or you can ask the buyer's conveyancer or solicitor to do it for you.


Requesting verification from the conveyancer lets you rely on the checks they have already carried out on the buyer, rather than repeating them. This is allowed under Rule 633 of the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Rules.


This article explains how to create the case, send the request to the conveyancer, complete the required risk assessment, and finish the case once the conveyancer responds.


Availability and requirements

  • Region: Australia. This workflow relies on Rule 633 of the AML/CTF Rules.
  • Who can do this: Agents, clients, and compliance admin users.
  • What you need before you start: The property address, the buyer's details (name, email address, and phone number if you have them), and the name of the buyer's conveyancer or solicitor. Ask the buyer who their conveyancer is if you do not already know.
  • Limitation: Requesting verification from the conveyancer covers the buyer's identity verification only. You still need to complete a separate risk assessment yourself before the case can move forward.


Create the case

Start a new case and enter the property and buyer details.


  1. Create a new case and enter the property address.
  2. Select Buyer from the party drop-down menu.
  3. Enter your AML due date. This is 28 days from the date the contract of sale is signed.
  4. Assign any users who need access to the case.
  5. Enter the buyer's name, email address, and phone number if you have them.
  6. Go to the Verification step.


Send the request to the conveyancer

At the Verification step, you choose who carries out the buyer's identity verification. You have two options:


  • Verify the buyer yourself. This is often the fastest route.
  • Request verification from the buyer's conveyancer or solicitor. Use this when the conveyancer has already verified the buyer.


To request verification from the conveyancer:


  1. Enter the conveyancer's name.
  2. Send the request. First AML emails the conveyancer and asks them to verify the buyer's information.


Complete the risk assessment

You still need to run a risk assessment on the buyer, even when the conveyancer is verifying their identity. The request to the conveyancer does not replace this step.


Complete the risk assessment while you wait for the conveyancer to respond. On the case, you then see the risk assessment marked as complete, alongside the open request to verify information.


What the conveyancer receives and does

The conveyancer does not need a First AML login to respond. This section explains what they see, so you know what to expect back.


The conveyancer receives an email from your agency asking them to verify information about the buyer. When they open the request, they see wording explaining that Rule 633 of the AML/CTF Rules allows this workflow. They are then taken to a form and asked to provide:


  • Their own name, reporting entity, phone number, and email address.
  • Confirmation that they have verified the buyer's identity.
  • Whether the buyer is acting on behalf of someone else.
  • The names of any beneficial owners.
  • How they collected or verified the buyer's identity documents.
  • Whether they checked if the buyer is a politically exposed person (PEP), and the level of risk they assessed.


Once the conveyancer completes the form and saves it, their answers are sent back to you in the First AML platform.


Complete the case

When the conveyancer responds, the request on your case updates to show the information has been received.


  1. Open the completed request to review the conveyancer's answers.
  2. If you are satisfied with the information, mark the request as complete. At this point you have obtained what you need under Rule 633 for the buyer.
  3. Move the case to Ready for Review.


Troubleshooting

The conveyancer says they did not receive the email. Check the email address on the request is correct, and ask them to look in their spam or junk folder. You can resend the request from the case if needed.


I want to verify the buyer myself instead. At the Verification step, choose to verify the buyer yourself rather than requesting verification from the conveyancer. This is often faster if the buyer is with you.


Can I move the case forward before doing the risk assessment? No. The request to the conveyancer only covers identity verification. You must complete the risk assessment yourself before the case can move to Ready for Review.