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AML/CTF Compliance Statement

How CapitalVue meets its obligations as a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), and what that means for you as a client.

Our obligations

From 1 July 2026, businesses that provide real estate buying and selling services in Australia became reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

CapitalVue is a reporting entity. We are enrolled with and regulated by AUSTRAC, the Australian Transaction Reports and Analysis Centre, which is Australia's financial crime regulator.

This is not an optional standard we have adopted. It is a legal obligation, and it applies to every client we act for, without exception.

What the law is designed to stop

Australian residential property is an attractive destination for criminal money. It absorbs large amounts in a single transaction, it holds value, and until 1 July 2026 the professionals involved in property transactions were largely outside the reporting net.

The reforms close that gap. They require us to understand who our clients are, who ultimately controls them, and where the money for a purchase is coming from, before we act.

We act for buyers, and the law reaches both sides

This is the part most people are not expecting, so we say it plainly.

CapitalVue is a buyers agency. We are engaged by purchasers. But the designated service captured by the Act is the brokering of a real estate purchase, and for that service AUSTRAC treats both the buyer and the seller as customers of the transaction.

In practice that means:

  • If you engage us as a buyer, we must complete our checks on you before we act for you.
  • When we negotiate on a property, we must also form a view about the other side of the transaction, and we will ask the selling agent for confirmation that their own customer checks have been completed.
  • If another agent asks us the same question about our client, we answer it. We confirm that our checks are complete. We do not hand over your documents or your personal information.

You may also be asked for identification by the selling agent, the conveyancer or solicitor, and the incoming lender. Each of them has their own obligation. We cannot complete their checks for them, and they cannot complete ours.

Customer due diligence, completed before we act

We are required to complete customer due diligence before we provide the service, not during it and not after settlement.

We will ask you for identification and supporting information at the point of engagement. We are not able to begin acting on your behalf, submit an offer, or negotiate on a property until those checks are complete. We know that is inconvenient when a property is moving quickly. It is not a discretion we hold.

What we may ask you for

Depending on who you are and how you are buying, we may ask for:

If you are buying in your own name

  • Full name, residential address and date of birth
  • A current photo identity document, such as an Australian driver licence or passport
  • Confirmation of the source of the funds for the purchase and your deposit

If you are buying through a company

  • The company's name, ACN and registered office
  • Identification for each director
  • Identification for each individual who ultimately owns or controls 25 per cent or more of the company
  • Identification for any other individual who controls the company

If you are buying through a trust or SMSF

  • The trust deed, or an extract of it
  • The full name and type of the trust
  • Identification for the trustee, and for the directors of a corporate trustee
  • Details of the beneficiaries, or of the class of beneficiaries
  • Details of the appointor, guardian or protector where the deed names one
  • Details of the settlor of the trust

We may also ask you about the purpose of the purchase, how it is being funded, and whether you or a close associate hold, or have held, a prominent public position.

If your circumstances change during our engagement, or if anything we have been told no longer appears accurate, we may need to ask again.

Where we collect information from

Most of what we hold comes directly from you.

We also check information against independent sources, including:

  • The Australian Securities and Investments Commission register, for company and officeholder details
  • The Department of Foreign Affairs and Trade Consolidated List, which is Australia's list of persons and entities subject to targeted financial sanctions
  • Other publicly available registers and sources, where they are relevant to confirming what we have been told

We do not use facial recognition or biometric matching, credit reporting information, or third-party electronic identity verification services. Our checks are carried out by a person, on documents and registers, and recorded.

Why we collect it

We collect this information to meet our obligations under the AML/CTF Act and the Rules made under it. Those obligations include identifying and verifying our customers and their beneficial owners, screening against sanctions lists, keeping records, and reporting certain matters to AUSTRAC.

What we do with it

We record it, we verify what the law requires us to verify, and we retain it. Our compliance officer reviews and signs off each customer file.

We do not use information collected for these purposes for marketing. It does not go to our mailing list, it is not used to profile you, and it is not sold or shared for any commercial purpose.

Who we share it with

We share information collected for AML/CTF purposes only where we are required or permitted to:

  • With AUSTRAC, where a reporting obligation arises
  • With law enforcement or a regulator, where we are required by law to do so
  • With our professional advisers, where we need advice on our obligations
  • With another party's agent, where we confirm to them that we have completed our checks. We confirm that fact and nothing more. We do not provide them with your identity documents or your personal details.

There are circumstances in which the law prohibits us from telling you that a report has been made. Where that applies, we will not do so.

Where it is held, and for how long

Information collected for AML/CTF purposes is held in Australia, in access-controlled storage in a Sydney data centre, separately from our general client records.

The Act requires us to keep these records for seven years. We apply that period from the end of our relationship with you, not from the date the document was provided.

Records held for this purpose are stored so that they cannot be deleted or altered within that period, including by us. That is deliberate. A record that can be quietly changed is not a record.

Privacy

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Our Privacy Policy explains how we collect, hold, use and disclose personal information generally, and how to request access to it or ask us to correct it.

Where the AML/CTF Act requires us to collect, retain or withhold information, those requirements take precedence, and we will tell you when that is the case.

If you give us information about someone else

If you provide us with information about another person, for example a co-purchaser, a director, a trustee or a beneficiary, please make sure they know that you have given it to us and why. Where it is practical, we will contact them directly.

If the information is not provided

If we cannot complete our customer due diligence, we cannot act. That is not a commercial decision on our part and it is not a judgement about you. It is the position the Act puts us in.

Where checks are incomplete, we will tell you exactly what is outstanding and help you resolve it.

Existing clients

The obligations apply to services provided from 1 July 2026. If we acted for you before that date and continue to act for you now, we may need to collect information we did not previously hold.

Questions

If you have a question about anything in this statement, or about information we hold about you, contact our AML/CTF Compliance Officer:

AML/CTF Compliance Officer
CapitalVue Pty Ltd
info@capitalvue.com.au
0499 484 727
28 Bovelles St, Camp Hill QLD 4152

Last updated: 24 September 2026. We review this statement at least annually and whenever our obligations change. This statement describes how CapitalVue meets its obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). It is general information only and is not legal advice.

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