Understand the Anti-Money Laundering (AML) Compliance Module

Prevent portal loading when AML is incomplete

You can optionally enforce a compliance gate that prevents a property from being uploaded to property portals if the vendor’s AML check is incomplete. This provides a hard stop to ensure properties do not go live online before AML requirements are met.

To enable the AML portal loading blocker:

• Go to: Settings > CRM
• Select AML/CTF Due Diligence settings
• Tick Prevent portal loading if vendor AML is incomplete

• Select Save

When this setting is enabled:

• Listings cannot be uploaded to portals if vendor AML is not completed
• The restriction applies only when AML is enabled
• Compliance is enforced at the point of portal upload

Use AML safeguards to block key workflow actions

In addition to preventing portal uploads, you can enable extra AML safeguards to stop users from progressing key sales and trust accounting actions when required AML checks are incomplete.

To configure these safeguards:

• Go to: Settings > CRM
• Select AML/CTF Due Diligence settings
• Tick any of the following options as required:
  • Prevent appraisal from being listed if appraisal contact AML is incomplete
  • Prevent entering unconditional dates if vendor AML is incomplete
  • Prevent entering unconditional dates if purchaser AML is incomplete
  • Prevent release of trust funds if vendor AML is incomplete
  • Prevent release of trust funds if purchaser AML is incomplete
  • Prevent trust release if purchaser AML has not started

• Click Save

Prevent appraisals from being listed when contact AML is incomplete

This safeguard prevents an appraisal from being converted into a listing until the appraisal contact's AML requirements have been completed.

When enabled:

• An appraisal cannot be listed if the appraisal contact's AML check is incomplete
• AML requirements can be completed before the appraisal progresses to a listing
• Compliance is enforced earlier in the sales workflow

Prevent entering unconditional dates when AML is incomplete

You can prevent unconditional dates from being entered until AML requirements have been satisfied.

Vendor and purchaser safeguards are configured independently, allowing you to enforce either or both requirements.

When enabled:

• Users cannot enter the actual unconditional date when vendor AML is incomplete
• Users cannot enter the actual unconditional date when purchaser AML is incomplete
• The safeguard helps ensure AML requirements are addressed before the sale progresses

Prevent releasing trust funds when AML is incomplete

You can prevent trust funds from being released until required AML checks have been completed.

Vendor and purchaser safeguards can be enabled separately.

When enabled:

• The Release Trust Funds option is unavailable when the required AML checks are incomplete
• A notification indicates that AML requirements have not been met
• Trust funds cannot be released until the applicable compliance requirements are satisfied

Prevent trust release if purchaser AML has not started

You can enable an alternative purchaser safeguard that prevents trust fund releases only when purchaser AML has not been started.

This safeguard differs from the purchaser AML incomplete safeguard. Instead of requiring purchaser AML to be fully completed, it requires evidence that the AML process has been initiated.

When enabled:

• Trust funds cannot be released if purchaser AML has not started
• Trust funds can be released once purchaser AML has been initiated, even if the AML process has not yet been completed
• This safeguard supports business processes where an attempted AML verification satisfies compliance obligations for trust fund release

"Pre-commencement customer" logic for Vendors

• If the listing was created before the 1st July, Vendor AML checks are not required under AUSTRAC rules. If any of our 'Prevent XYZ if Vendor AML is incomplete' Safeguards are enabled, the listing will be excluded and users will not be prevented from taking that action
• If the listing was created on or after the 1st July, and one or more Vendor AML checks are missing or not complete, if any of our 'Prevent XYZ if Vendor AML is incomplete' Safeguards are enabled, the listing will be included and users will be blocked from taking that action
• If the listing was created on or after the 1st July, and all Vendors have a completed AML check, if any of our 'Prevent XYZ if Vendor AML is incomplete' Safeguards are enabled, users will be allowed to take that action

"Pre-commencement customer" logic for Purchasers

• If the Purchaser Activity date is before the 1st July, Purchaser AML checks are not required under AUSTRAC rules. If any of our 'Prevent XYZ if Purchaser AML is incomplete' Safeguards are enabled, the listing will be excluded and users will not be prevented from taking that action
• If the Purchaser activity date is on or after the 1st July, and one or more Purchaser AML checks are missing or not complete, if any of our 'Prevent XYZ if Purchaser AML is incomplete' Safeguards are enabled, the listing will be included and users will be blocked from taking that action
• If the listing was created on or after the 1st July, and all Purchasers have a completed AML check, if any of our 'Prevent XYZ if Purchaser AML is incomplete' Safeguards are enabled, users will be allowed to take that action