AML/CTF Compliance & Client Verification
Protecting our clients and the integrity of Australian property
From 1 July 2026, Australia’s Anti-Money Laundering and Counter-Terrorism Financing laws apply to a broader range of professional and real estate services, including certain property acquisition and buyer’s agency services.
As part of National Investment Advisory’s regulatory obligations, we are required to undertake appropriate Customer Due Diligence and, where required, verify the identity of clients before providing certain regulated property services.
National Investment Advisory uses First AML, our approved electronic AML/CTF verification platform, to support identity verification, Know Your Customer checks and associated compliance requirements.
Our aim is to make the process secure, straightforward and as easy as possible for our clients.
Why is NIA requesting this information?
Anti-Money Laundering and Counter-Terrorism Financing — commonly referred to as AML/CTF — laws are designed to prevent legitimate businesses, financial systems and property transactions from being used to conceal criminal proceeds, finance terrorism or facilitate other serious financial crime.
As a business providing property acquisition and related services, National Investment Advisory has obligations under Australia’s AML/CTF regime.
These obligations can include:
- Identifying and verifying clients
- Understanding who owns or controls companies, trusts and other entities
- Understanding the nature and purpose of a client relationship or transaction
- Assessing AML/CTF risk
- Conducting appropriate screening and Customer Due Diligence
- Obtaining further information where required
- Maintaining appropriate compliance records
AML/CTF verification is therefore a normal part of NIA’s client onboarding and ongoing compliance process.
How does the NIA verification process work?
1. Your NIA engagement
When you decide to proceed with National Investment Advisory, your Property Wealth Strategist and Client Success Coordinator will explain the next steps in your onboarding process, including any AML/CTF requirements that apply.
2. Secure verification request
Where verification is required, you will receive a secure electronic verification request through First AML, NIA’s approved AML/CTF verification platform.
Please complete your verification through the secure link provided.
For your security, please do not email copies of passports, driver’s licences or other sensitive identification documents to NIA unless specifically requested through an approved process.
3. Identity and Customer Due Diligence
Depending on your circumstances and purchasing structure, the process may include:
- Electronic identity verification
- Know Your Customer information
- Verification of a company, trust, SMSF or other entity
- Identification of beneficial owners or persons who control an entity
- Politically Exposed Person screening
- Sanctions screening
- Adverse media screening
- AML/CTF risk assessment
For most individual clients, the initial verification process should be relatively straightforward.
Where a company, trust, SMSF, overseas party or more complex ownership or funding structure is involved, some additional information may be required.
4. Verification completed
Once the required AML/CTF checks have been satisfactorily completed, NIA can confirm your compliance status and progress the relevant next stages of your property investment journey.
What information may be requested?
The information required will depend on who is purchasing the property, the ownership structure, the nature of the transaction and the applicable AML/CTF requirements.
For an individual, information may include:
- Full legal name
- Date of birth
- Residential address
- Occupation or employment information
- Government-issued identification information
- Other information required to establish and verify identity
Where a property is being purchased through a company, trust, Self-Managed Super Fund, partnership or another legal entity, additional information may be required regarding:
- The legal entity
- Trustees
- Directors
- Shareholders or members
- Beneficial owners
- Persons exercising effective control
- Persons authorised to act on behalf of the entity
- Relevant company, trust or SMSF documentation
The amount of information required will vary depending upon the circumstances.
Companies, Trusts and SMSFs
Many NIA clients purchase property using structures such as companies, family trusts or Self-Managed Super Funds.
If an entity is involved in the property transaction, AML/CTF requirements may require NIA to understand and verify both the entity and the individuals who ultimately own, control or act on its behalf.
For example, we may need information regarding:
- Directors
- Trustees
- Beneficial owners
- Authorised representatives
- Persons exercising effective control
This is a standard component of AML/CTF Customer Due Diligence and does not mean there is a concern with you or your proposed property transaction.
Source of Funds
In some circumstances, NIA may need to understand or verify the Source of Funds being used in a property transaction. Source of Funds refers to how the money being used for the particular transaction was obtained.
Examples may include:
- Salary or employment income
- Business income
- Accumulated savings
- Investment income
- Sale of another property or asset
- Equity released from an existing property
- An inheritance
- A gift
- Borrowed funds or finance
- Other legitimate sources
Not every client will be required to provide extensive Source of Funds documentation.
The level of information required will depend upon the circumstances of the transaction and applicable AML/CTF risk requirements.
Source of Wealth
In certain circumstances, we may also need information regarding Source of Wealth.
Source of Wealth refers more broadly to how a person has accumulated their overall wealth, assets or financial position.
This could include wealth accumulated through:
- Employment
- Business ownership
- Investments
- Property
- Inheritance
- Other legitimate means
Source of Wealth enquiries are generally made where required by the circumstances or AML/CTF risk assessment rather than as an extensive exercise for every NIA client.
If additional information is required, NIA or First AML will explain what is needed.
Gifts, third-party funds and overseas funds
If another person is contributing money towards your property purchase, your deposit includes gifted funds or funds are being transferred from overseas, additional information may be required.
This can include understanding:
- Who is providing the funds
- The relationship between the parties
- Why the funds are being provided
- The origin or source of the funds
This does not automatically prevent a transaction from proceeding.
Providing the information early helps NIA complete any required checks and minimise unnecessary delays later in the property acquisition process.
Your privacy and personal information
National Investment Advisory takes the privacy and security of client information seriously.
Information collected for AML/CTF purposes is handled in accordance with applicable legal and privacy obligations and NIA’s privacy and information security procedures.
NIA uses First AML to support our electronic identity verification and AML/CTF Customer Due Diligence processes.
First AML processes personal information on behalf of businesses such as NIA to undertake identity verification and other AML/CTF compliance checks.
For Australian verification processes, information can include personal details, identification information and, where the electronic verification process requires it, biometric information used for identity verification.
First AML provides detailed information regarding how personal information is collected, processed, secured, retained and managed in its Privacy Policy.
First AML also publishes information regarding its Security practices, including technical and organisational safeguards used to protect information.
Clients can review:
You can also refer to National Investment Advisory’s Privacy Policy for information regarding how NIA handles personal information.
For your protection, identification information should be submitted through the secure verification process provided rather than through ordinary email unless specifically requested through an approved process.
How long is AML/CTF information retained?
Australian AML/CTF legislation requires certain AML/CTF records to be retained for prescribed periods.
Depending on the record and circumstances, this can include retaining relevant AML/CTF records for seven years following the end of the applicable business relationship or completion of the relevant transaction.
NIA and its AML/CTF service providers manage AML/CTF records in accordance with applicable legal, privacy and document-retention requirements.
This does not necessarily mean that complete copies of identity documents such as passports or driver’s licences must be retained for the entire period.
NIA’s systems and procedures are designed to retain the information and verification records required for AML/CTF compliance while also taking account of privacy and information-security obligations.
What happens if I don’t complete AML verification?
Where AML/CTF verification or Customer Due Diligence is required, National Investment Advisory may be unable to commence or continue certain regulated property acquisition services until the required process has been satisfactorily completed.
This is a regulatory requirement and not simply an NIA administrative process.
If you have difficulty completing your verification, please contact our Client Success team.
We can help determine what additional information or assistance may be required.
Existing NIA clients
AML/CTF obligations also include ongoing Customer Due Diligence.
If you became an NIA client before the commencement of the new requirements, NIA may contact you as part of our ongoing AML/CTF compliance framework.
We may ask you to:
- Confirm information already held
- Update information that has changed
- Reverify specific information where required
- Provide information regarding a new transaction
- Update information relating to a company, trust or SMSF
- Complete additional AML/CTF verification where required
Receiving such a request does not mean that NIA has identified a problem or concern with you.
It forms part of NIA’s responsibility to maintain appropriate, accurate and current Customer Due Diligence information.
Frequently Asked Questions
AML/CTF means Anti-Money Laundering and Counter-Terrorism Financing.
Australia’s AML/CTF laws are designed to prevent legitimate businesses, financial systems and transactions from being exploited for money laundering, terrorism financing and other serious financial crime.
Property transactions can potentially be used to transfer, conceal or legitimise illegally obtained funds.
Australia’s AML/CTF framework therefore applies to certain services involved in the acquisition, sale and transfer of real estate.
This includes certain services provided by real estate professionals and buyer’s agents.
No.
Identity verification and Customer Due Diligence are standard compliance processes.
They are undertaken across NIA’s relevant client relationships and are not an indication that NIA suspects a particular client of wrongdoing.
NIA has legal obligations to understand who its customers are and to undertake appropriate Customer Due Diligence before providing certain regulated services.
Identity verification is one part of that process.
For many individual clients, electronic verification can be completed relatively quickly.
More complex structures — including companies, trusts and SMSFs — can require additional information.
If First AML or NIA requires anything further, we will let you know.
For many individual clients, the process may involve government-issued identification such as a driver’s licence or passport together with electronic identity verification.
The exact information required can vary.
First AML will guide you through the steps required for your verification.
Where a company, trust, SMSF or other legal entity is involved, AML/CTF requirements may require NIA to identify and understand both the entity and the people who ultimately own, control or act for it.
This can include directors, trustees, beneficial owners and authorised representatives.
A beneficial owner is generally an individual who ultimately owns or controls an entity.
Understanding who ultimately controls companies and other legal structures is an important component of Customer Due Diligence.
Banks, mortgage brokers, solicitors, conveyancers, real estate professionals and other regulated businesses may each have their own AML/CTF responsibilities.
In some circumstances, the law allows one regulated business to rely on Customer Due Diligence undertaken by another reporting entity, provided the applicable requirements are satisfied.
Whether NIA can rely on another party’s verification will depend on the individual circumstances.
Unless NIA advises you otherwise, please complete the verification request we send you.
Source of Funds refers to how the money being used for a particular property transaction was originally obtained.
NIA may need to understand this as part of its Customer Due Diligence and AML/CTF risk assessment.
Being asked about Source of Funds does not mean that there is anything unusual or wrong with your transaction.
Source of Wealth refers more broadly to how you accumulated your overall wealth or assets.
This information may be required in certain circumstances as part of enhanced Customer Due Diligence or risk assessment.
It is not necessarily required to the same extent for every client.
Please tell NIA or First AML.
Where another person is providing part of the funds used for a transaction, additional information may be required regarding that person and the source of the money.
This is a normal AML/CTF consideration and does not automatically prevent your transaction from proceeding.
Overseas funds may require some additional information.
Please disclose this when requested so that any required checks can be completed early and unnecessary delays can be avoided.
NIA uses First AML as our approved electronic AML/CTF verification platform.
First AML publishes detailed privacy and security information regarding how information is collected, processed and protected.
Its published security measures include encryption, access controls, security monitoring and information-security controls.
For additional information, refer to the First AML Privacy Policy and First AML Security information linked on this page.
Electronic identity verification may involve comparing your face with the image contained in an identification document.
Where biometric information is used, First AML states that it is used for identity verification and identity-fraud prevention purposes.
Further information is available in First AML’s Privacy Policy.
Certain AML/CTF records must be retained for prescribed periods under Australian law.
Relevant AML records may need to be retained for seven years following the end of the applicable business relationship or completion of the relevant transaction.
NIA and First AML manage these records in accordance with applicable AML/CTF, privacy and information-security requirements.
AML/CTF obligations include maintaining appropriate and current information throughout relevant customer relationships.
NIA may therefore contact existing clients to confirm or update information, conduct ongoing Customer Due Diligence or undertake additional verification where required.
This is part of our normal AML/CTF compliance framework.
Not necessarily.
Before providing further regulated services, NIA may review the Customer Due Diligence information already held.
If your information remains current and appropriate, limited or no additional information may be required.
If your circumstances, ownership structure, transaction or AML/CTF risk has changed, NIA may need to obtain updated information or undertake further verification.
Sometimes electronic systems cannot automatically verify particular information.
That does not automatically mean that your NIA engagement cannot proceed.
First AML or NIA will advise you if an alternative verification method or additional information is required.
If NIA cannot satisfactorily complete required Customer Due Diligence, we may be unable to commence or continue the regulated service.
Where additional information has been requested and you’re unsure why it is required, please speak with our Client Success team before deciding not to proceed.
If you have questions about NIA’s AML/CTF verification process or are having trouble completing your verification, please contact:
National Investment Advisory
Client Success / AML Team
Our team will assist you with the next steps.
Visit our home page by clicking www.nationalinvestmentadvisory.com.au
Important Information
National Investment Advisory’s AML/CTF procedures are designed to meet applicable Australian AML/CTF legislation and regulatory requirements.
The information provided on this page is general information about NIA’s AML/CTF compliance and client-verification processes. It does not constitute legal, taxation or financial advice.
AML/CTF requirements can vary depending upon the customer, ownership structure, transaction, source of funds and assessed risk.
NIA may therefore request additional information or verification where reasonably required to satisfy its AML/CTF obligations.