Guides · Updated 23 Sept 2026

AML/CTF and auction day: what an agent must have done before the hammer falls

Auctions compress a sale into an afternoon. The due diligence cannot be compressed with it, so the work happens at engagement and the record is finished on the day.

A tidy accounting practice desk with a closed laptop, a navy ledger and client folders with teal tabs, city buildings in the window.

Before the campaign

The vendor is your customer. Identify and verify them, and the beneficial owners of any company or trust, when the agency agreement is signed. Record the purpose and rate the risk.

On the day

Record who the successful bidder is and how the deposit is paid. Follow AUSTRAC's real estate guidance on what identification is expected of the buyer when you act for the vendor. A cash deposit of AU$10,000 or more into your trust account is a threshold transaction: report within 10 business days.

Red flags at auction

  • A bidder who wants to pay the deposit in cash.
  • A third party paying the deposit for no clear reason.
  • A buyer who will not give a name or gives details that do not match.
  • Pressure to settle unusually fast, or an unusual price with no explanation.

Questions people ask

Can we accept a cash deposit at auction?
You can, unless your program says otherwise. If it is AU$10,000 or more you must lodge a threshold transaction report within 10 business days. Many agencies simply do not accept cash deposits and say so in their program.

This guide is general information for real estate agents, buyers agents, property managers, not legal advice. Check AUSTRAC's current guidance for your situation.

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AML/CTF and auction day: what an agent must have done before the hammer falls · RealtyAML