AMLify's EDD Workflow for Real Estate Agents
AMLify triggers enhanced due diligence automatically for high-risk property buyers, capturing source-of-wealth evidence and AMLCO sign-off in one workflow.
When a buyer or seller in a property transaction presents elevated ML/TF risk, AMLify automatically routes the client file into an enhanced due diligence (EDD) workflow — prompting extra evidence, flagging the file for senior sign-off, and recording every decision before settlement proceeds.
When does a real estate transaction need EDD?
Standard CDD is not enough once a client or transaction shows one or more elevated risk indicators. Under the AML/CTF Act 2006, agents must apply EDD when: - The buyer or seller is a politically exposed person (PEP) — domestic or foreign - Settlement funds arrive from an unexplained third party with no documented relationship to the transaction - The client is a non-resident connected to a FATF high-risk jurisdiction - Beneficial ownership is unclear after reasonable enquiry into a company or trust buyer - The purchase price or payment structure is inconsistent with the client's known profile
How does AMLify's EDD workflow work?
AMLify surfaces the EDD trigger the moment a risk flag is raised — during initial screening or later re-screening — and walks the agent through a structured, auditable process: 1. Automatic trigger — a PEP match, sanctions hit, or risk-rating change opens the EDD workflow directly from the client file, no separate system to check 2. Source-of-wealth capture — the workflow prompts for documented evidence of where settlement funds originated, not just source-of-funds for the transaction itself 3. Senior sign-off — the file cannot proceed to settlement until a named senior officer records an approval decision 4. Decision trail — the reasoning, evidence reviewed, and approver are timestamped and stored against the client record for at least seven years
Because the EDD workflow sits inside the same client file as standard CDD, agents are not toggling between spreadsheets and email approvals under time pressure before settlement.
What happens if EDD is skipped?
AUSTRAC's early Tranche 2 reviews have focused heavily on whether EDD was actually applied where it was required — not just whether a firm's written programme mentions it. A programme that lists EDD triggers on paper but has no working process to apply them before settlement leaves a real estate agency exposed to enforcement action, and settlement itself does not pause for compliance to catch up afterwards. Building the trigger into the transaction workflow, rather than relying on staff to remember it, is what closes that gap. See AMLify for real estate agents for the full workflow.
Key Takeaways
- EDD is mandatory, not optional, for PEPs, unexplained third-party funds, unclear beneficial ownership, and high-risk jurisdiction connections
- AMLify triggers EDD automatically from the same risk flag that would otherwise sit in a screening report unread
- Source-of-wealth evidence and senior sign-off are captured before settlement, not reconstructed afterwards
- Every EDD decision is timestamped and retained, giving agencies an audit-ready record if AUSTRAC reviews the file
- Get compliant now — a 14-day free trial at /pricing puts the EDD workflow inside your existing transaction process
Frequently Asked Questions
Q: Who decides whether EDD applies to a transaction?
Your AML/CTF programme's Part B must define the risk indicators that trigger EDD. AMLify applies those triggers automatically based on screening results and client data, then routes the file to the senior officer named in your programme for the approval decision.
Q: Is EDD the same as beneficial ownership verification?
No. Beneficial ownership mapping is part of standard CDD for entity clients. EDD is an additional layer of scrutiny — extra evidence and senior approval — applied on top of standard CDD when a specific risk indicator is present.
Q: How long must EDD records be kept?
Records supporting an EDD decision, including the evidence reviewed and the approver's reasoning, must be retained for at least seven years, in a format that is searchable and available for AUSTRAC review.
Q: Does EDD apply to sellers as well as buyers?
Yes. The obligation applies to whichever party the real estate agent is providing the designated service to. If a seller presents a risk indicator — for example, an unclear beneficial ownership structure behind a corporate vendor — the same EDD process applies.
This is general information only and not a substitute for legal advice.