Real Estate - Customer Onboarding

Overview

This guide covers FrankieOne’s KYC solution for real estate professionals, designed to support identity verification obligations for real estate agents, conveyancers, and property transaction participants under current and upcoming AML/CTF requirements.

Summary

Available Workflows

Workflow	Purpose	When to Use
`AUS-Basic3V-TwoPlusID`	Individual verification	Buyers, sellers (individuals)
`AUS-Business-KYB`	Entity verification	Companies, trusts, partnerships
`AUS-PEP-Sanctions-Media`	Enhanced screening	High-value, higher-risk transactions

Verification by Party Type

Party	Workflow	Timing
Individual Seller	`AUS-Basic3V-TwoPlusID`	Listing agreement
Individual Buyer	`AUS-Basic3V-TwoPlusID`	Offer/contract
Company/Trust Seller	`AUS-Business-KYB` + individual verification	Listing agreement
Company/Trust Buyer	`AUS-Business-KYB` + UBO verification	Offer/contract
Foreign Purchaser	Enhanced verification + FIRB check	Offer/contract

Risk-Based Approach

Risk Factors

Factor	Lower Risk	Higher Risk
Transaction value	Under $1M	Over $5M
Property type	Residential	Commercial, development
Buyer type	Australian individual	Foreign entity, complex structure
Payment method	Bank transfer (domestic)	Cash, offshore funds, crypto
PEP/sanctions	Clear	Matches or near-matches

Verification Checklists

Individual:

Full legal name ✓
Date of birth ✓
Residential address ✓
Government ID ✓
PEP/sanctions screening ✓

Entity:

Entity name and registration ✓
Directors/trustees ✓
Beneficial owners over 25% ✓
Each UBO verified ✓
PEP/sanctions screening (all) ✓

Support

Documentation: docs.frankieone.com
Support: Contact your FrankieOne representative

Expanded Details

Regulatory Context

Disclaimer: The information in this section is provided for general guidance only and does not constitute legal or compliance advice. Customers must seek independent legal and regulatory advice to ensure their implementation meets their specific regulatory obligations. FrankieOne is not responsible for customers’ compliance decisions or outcomes.

Regulatory Updates: The Australian Government is implementing AML/CTF Tranche 2 reforms that will bring real estate professionals under AUSTRAC reporting obligations. Customers should monitor updates from AUSTRAC and prepare for compliance requirements.

AML/CTF Tranche 2 - Real Estate

Real estate has been identified as a high-risk sector for money laundering. Tranche 2 reforms will extend AML/CTF obligations to:

Covered Entity	Expected Obligations
Real Estate Agents	Customer identification, suspicious matter reporting, AML/CTF program
Conveyancers	Customer identification, transaction monitoring, reporting
Property Developers	Customer due diligence for off-plan sales
Settlement Agents	Customer identification, fund source verification

Expected Obligations Under Tranche 2

Obligation	Requirement	How FrankieOne Can Support
Customer Identification	Verify identity of buyers, sellers, and beneficial owners	Automated identity verification workflows
Beneficial Ownership	Identify and verify beneficial owners of entities	Business verification and UBO identification
Ongoing CDD	Risk-based ongoing customer due diligence	Screening refresh and re-verification (where configured)
AML/CTF Program	Establish and maintain compliant program	Configurable risk rules aligned to your program
Suspicious Matter Reporting	Report suspicious matters to AUSTRAC	Audit trails and exportable verification data
Record Keeping	Maintain verification records for 7 years	Secure record retention

Current Industry Obligations

Even before Tranche 2, real estate professionals have verification obligations:

Source	Requirement
Real Estate Institute Codes	Client identification best practices
State Licensing Requirements	Varies by jurisdiction
Anti-Money Laundering Guidance	Industry guidance on suspicious transactions
Foreign Investment (FIRB)	Foreign purchaser identification

Workflow Configuration Details

Individual Verification: `AUS-Basic3V-TwoPlusID`

Standard identity verification for individual buyers and sellers. Core Checks:

Check Type	Purpose
Government ID verification (DVS)	Primary identity confirmation
Credit bureau check	Identity cross-reference
Electoral roll	Address verification
PEP and sanctions screening	AML risk assessment

Business Verification: `AUS-Business-KYB`

Verification for companies, trusts, and other entities involved in property transactions. Entity Verification Components:

Component	Description
Entity existence	ASIC/ABR verification
Entity details	Name, registration, status
Directors/officeholders	Identification of key persons
Beneficial owners	Individuals with over 25% ownership/control
Trust structures	Trustee and beneficiary identification

Enhanced Screening: `AUS-PEP-Sanctions-Media`

Enhanced screening for higher-risk transactions. Screening Components:

Check	Description
PEP screening	Politically Exposed Persons (Levels 1-4)
Sanctions screening	DFAT, UN, OFAC, EU lists
Adverse media	Negative news screening
Watchlists	Law enforcement lists

Step-by-Step Implementation

Note: This section describes the conceptual implementation flow. For actual API endpoints and schemas, refer to the FrankieOne API Documentation.

Seller Verification Flow

Step 1: Verify Seller Identity For individual sellers:

Full legal name
Date of birth
Residential address
Government ID verification

For entity sellers:

Entity verification (company/trust)
Director/trustee identification
Beneficial owner verification
Authority to sell

Step 2: Verify Authority to Sell

Scenario	Verification Required
Sole owner	Title search confirmation
Joint owners	All owners verified
Company owner	Director authority, company verification
Trust owner	Trustee authority, trust verification
Deceased estate	Executor verification, probate
Power of Attorney	POA document, attorney verification

Buyer Verification Flow

Step 1: Verify Buyer Identity For individual buyers:

Full legal name
Date of birth
Residential address
Government ID verification

For entity buyers:

Entity verification
Beneficial owner identification
All UBOs with over 25% ownership verified

Step 2: Beneficial Ownership Verification Step 3: Foreign Purchaser Verification

Requirement	Verification
FIRB approval	Confirm approval obtained
Passport verification	Foreign passport + visa if applicable
Overseas address	Address verification or document
Source of funds	May require enhanced due diligence

Risk Tier Examples

Tier 1: Low Risk - Standard CDD

Transaction Profile:

Australian individual seller
Australian individual buyer
Residential property $650,000
Bank transfer from domestic account

Example Scenario:

James Testone sells his Sydney apartment to Mary Testtwo for $650,000. Both are Australian citizens with verified identities. Standard CDD completed. Funds transferred from Mary’s domestic bank account. Transaction proceeds.

Tier 2: Medium Risk - Enhanced CDD

Transaction Profile:

Company seller (investment property)
Foreign individual buyer
Property value $1.8M
FIRB approval required

Example Scenario:

TestCorp Pty Ltd (verified company, directors identified) sells Melbourne property to Hans Testthree, a German national with FIRB approval. Enhanced due diligence performed: foreign passport verified, FIRB approval confirmed, PEP/sanctions screening clear. Transaction proceeds with enhanced documentation.

Tier 3: High Risk - Senior Approval Required

Transaction Profile:

Complex trust structure seller
Offshore company buyer
High-value commercial property $12M
PEP Level 3 identified in ownership structure

Example Scenario:

A family trust sells commercial property to an offshore company. Trust has 5 beneficiaries requiring verification. Buyer’s UBO structure reveals a PEP Level 3 (family member of political figure). Enhanced due diligence required: all beneficiaries verified, offshore company structure documented, source of funds investigated. Senior management approval required before proceeding.

Edge Cases and Special Handling

Complex Ownership Structures

Structure	Verification Approach
Discretionary Trust	Trustee + appointor + beneficiary classes
Unit Trust	Trustee + unit holders over 25%
SMSF	Corporate trustee/individual trustees + members
Foreign Trust	Equivalent to Australian requirements
Multi-layered Structures	Verify through to ultimate beneficial owners

Authorised Representatives

Scenario	Verification Required
Power of Attorney	POA document verification, attorney ID
Company representative	Authority confirmation, representative ID
Solicitor acting	Law society verification, solicitor ID
Buyer’s agent	Authority letter, agent ID

Deceased Estates

Document	Purpose
Death certificate	Confirm death
Probate/Letters of Administration	Authority to sell
Executor ID verification	Identity of authorised person

Property-Specific Considerations

Property Type	Additional Considerations
Off-the-plan	Developer verification, sunset clauses
Auction	Time-sensitive verification
Commercial	Higher value thresholds, tenant verification
Rural/agricultural	Water rights, foreign ownership restrictions

Beneficial Ownership

Identifying Beneficial Owners

Under expected Tranche 2 requirements, beneficial owners are individuals who:

Own over 25% of the entity (directly or indirectly)
Control over 25% of voting rights
Exercise significant control over the entity

Verification Requirements:

UBO Category	Verification
Direct shareholders over 25%	Standard individual verification
Indirect owners over 25%	Trace through to individual, verify
Controlling persons	Verify identity, document control
Trust beneficiaries	Named beneficiaries or classes

Common Entity Structures

Compliance Reporting

Record Keeping Requirements

Under expected Tranche 2 requirements, records must be kept for 7 years. Records to Maintain:

Record Type	Details
Customer identification	Verification records, documents collected
Transaction records	Property details, values, parties
Risk assessments	Risk rating, rationale
Screening results	PEP/sanctions checks
Suspicious matter reports	Internal records (reports filed with AUSTRAC)

Suspicious Matter Indicators

Real estate professionals should be alert to:

Indicator	Example
Unusual payment arrangements	Cash deposits, third-party payments
Price anomalies	Significantly above/below market value
Rapid transactions	Quick buy/sell sequences
Reluctance to provide information	Avoiding verification
Complex structures	Unnecessarily complex ownership
High-risk jurisdictions	Funds or parties from high-risk countries

Troubleshooting

Issue	Likely Cause	Resolution
Entity verification failing	Incorrect ABN/ACN	Verify registration details
UBO identification incomplete	Complex trust structure	Request trust deed, trace ownership
Foreign passport verification	Document not supported	Request alternative ID or document verification
FIRB approval not confirmed	Timing issue	Confirm with buyer’s solicitor

​Overview

​Summary

​Available Workflows

​Verification by Party Type

​Risk-Based Approach

​Risk Factors

​Verification Checklists

​Support

​Expanded Details

​Regulatory Context

​AML/CTF Tranche 2 - Real Estate

​Expected Obligations Under Tranche 2

​Current Industry Obligations

​Workflow Configuration Details

​Individual Verification: AUS-Basic3V-TwoPlusID

​Business Verification: AUS-Business-KYB

​Enhanced Screening: AUS-PEP-Sanctions-Media

​Step-by-Step Implementation

​Seller Verification Flow

​Buyer Verification Flow

​Risk Tier Examples

​Tier 1: Low Risk - Standard CDD

​Tier 2: Medium Risk - Enhanced CDD

​Tier 3: High Risk - Senior Approval Required

​Edge Cases and Special Handling

​Complex Ownership Structures

​Authorised Representatives

​Deceased Estates

​Property-Specific Considerations

​Beneficial Ownership

​Identifying Beneficial Owners

​Common Entity Structures

​Compliance Reporting

​Record Keeping Requirements

​Suspicious Matter Indicators

​Troubleshooting

Overview

Summary

Available Workflows

Verification by Party Type

Risk-Based Approach

Risk Factors

Verification Checklists

Support

Expanded Details

Regulatory Context

AML/CTF Tranche 2 - Real Estate

Expected Obligations Under Tranche 2

Current Industry Obligations

Workflow Configuration Details

Individual Verification: `AUS-Basic3V-TwoPlusID`

Business Verification: `AUS-Business-KYB`

Enhanced Screening: `AUS-PEP-Sanctions-Media`

Step-by-Step Implementation

Seller Verification Flow

Buyer Verification Flow

Risk Tier Examples

Tier 1: Low Risk - Standard CDD

Tier 2: Medium Risk - Enhanced CDD

Tier 3: High Risk - Senior Approval Required

Edge Cases and Special Handling

Complex Ownership Structures

Authorised Representatives

Deceased Estates

Property-Specific Considerations

Beneficial Ownership

Identifying Beneficial Owners

Common Entity Structures

Compliance Reporting

Record Keeping Requirements

Suspicious Matter Indicators

Troubleshooting