AML/CTF and Identity Verification

This Privacy Collection Notice explains how Somners Pty Ltd (referred to as "Somners", "we", "us" or "our") collects and handles personal information when carrying out customer due diligence under Australia's anti-money laundering and counter-terrorism financing laws.

This notice applies when we collect personal information to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the Anti-Money Laundering and Counter-Terrorism Financing Rules and related legal requirements. It should be read together with our Privacy Policy, which provides further information about how we handle personal information across our business.

Why Real Estate Agents Need To Verify Identity

From 1 July 2026, anti-money laundering and counter-terrorism financing obligations apply to real estate professionals who provide designated services involving the brokering of the sale, purchase or transfer of Australian real estate.

These laws require Somners to undertake customer due diligence when we provide a designated service. Customer due diligence is used to establish who our customers are, verify relevant information about them, understand relevant ownership or control arrangements, assess applicable money laundering, terrorism financing and proliferation financing risks, and meet associated legal, reporting and record-keeping requirements.

For AML/CTF purposes, when Somners brokers the sale, purchase or transfer of real estate, both the seller or transferor and the buyer or transferee are treated as customers of the designated service. This means Somners is required to undertake customer due diligence on both parties, even though we will ordinarily have been appointed to act for only one of them.

For example, where Somners acts as the seller's agent, we must undertake customer due diligence on the seller and, if a transaction proceeds, on the buyer. The AML/CTF laws allow customer due diligence on the party we do not act for to be completed at a later stage in certain circumstances.

Why We Collect Your Personal Information

We collect personal information for the purpose of complying with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and associated Rules.

This includes establishing and verifying identity, establishing the identity of relevant beneficial owners, representatives or other specified persons where required, understanding the nature and purpose of a relevant business relationship or transaction, assessing and managing money laundering, terrorism financing and proliferation financing risks, carrying out ongoing customer due diligence where required, meeting reporting obligations and maintaining records required by law.

The amount and type of information we need will depend on the circumstances, the type of customer, the nature of the transaction and the level of risk associated with providing the designated service.

Information We May Collect

For an individual, information collected for customer due diligence may include your full name, date of birth, residential address and information contained in identification documents such as a driver licence or passport. This can include an identification document number, issuing authority, expiry date or other information reasonably necessary to establish and verify your identity.

Where required by our customer due diligence obligations or having regard to the circumstances and assessed risk, we may also need information about your occupation or employment, the purpose and nature of a transaction or business relationship, the source of funds or source of wealth, your authority to act for another person, or other information reasonably necessary for us to comply with the AML/CTF laws.

Where the customer is a company, trust, partnership, association or another type of organisation, we may collect information about the entity itself and the people associated with it. This can include information about directors, trustees, partners, beneficial owners, persons exercising control, representatives, agents and other people whose identity or role must be established under the AML/CTF laws.

We may also collect information reasonably necessary to determine whether an individual is a politically exposed person, is subject to applicable targeted financial sanctions, or presents another circumstance relevant to our AML/CTF obligations.

We will only request additional personal information where it is reasonably necessary to satisfy our customer due diligence obligations or address circumstances relevant to the assessed AML/CTF risk.

How We Collect And Verify Information

We will generally collect personal information directly from you, including through identification and customer due diligence forms, documents you provide, electronic communications, face-to-face interactions or electronic identity verification processes.

We may verify information using reliable and independent data sources and may use appropriate identity verification, compliance or technology services to assist with that process. Depending on the verification method used, information may be checked against government, commercial or other reliable and independent sources.

We may also obtain information from publicly available sources and appropriate registers, including company, trust, property, professional, regulatory or government information sources where relevant to our obligations.

Where you are acting for another person or entity, we may obtain information from you about that person or entity and may need to verify that information independently. Information may also be obtained from authorised representatives, solicitors, conveyancers, accountants or other people or organisations involved in a transaction where permitted by law.

When Customer Due Diligence Takes Place

Somners will generally complete initial customer due diligence on the party we act for before we begin providing the relevant designated service.

Different timing rules can apply to the other party to a real estate transaction. The AML/CTF laws may allow Somners to delay completing initial customer due diligence on the party we do not act for, provided the applicable requirements for delayed customer due diligence are satisfied. Where customer due diligence is delayed, it must be completed as soon as reasonably practicable and no later than the applicable deadline under the AML/CTF laws.

What Happens If You Do Not Provide The Information?

Where Somners is legally required to establish or verify information about you, failure to provide sufficient information may prevent us from satisfying our customer due diligence obligations.

Depending on the circumstances, this may mean that we cannot commence or continue providing a designated service, that we need to obtain information from another permitted source, or that we must take other steps required by the AML/CTF laws and our AML/CTF program.

Who We May Disclose Information To

We may disclose personal information where reasonably necessary to carry out customer due diligence, verify information, operate our compliance systems or meet our obligations under the AML/CTF laws.

This may include disclosure to service providers assisting Somners with identity verification, compliance, technology or professional services where those services are used as part of our AML/CTF processes.

We may also disclose personal information to the Australian Transaction Reports and Analysis Centre (AUSTRAC), law enforcement agencies, regulatory authorities, government agencies or other bodies where disclosure is required or authorised by law.

Legal Restrictions On What We Can Tell You

Australian AML/CTF law places restrictions on the disclosure of certain information where disclosure would or could reasonably be expected to prejudice an investigation.

As a result, there may be circumstances in which Somners is prohibited from telling you about particular compliance activities, reports, information requests, investigations or disclosures. Nothing in this notice or our Privacy Policy requires Somners to provide information where doing so would be prohibited by law.

How Long We Keep AML/CTF Information

The AML/CTF legislation requires Somners to create and retain records demonstrating compliance with our customer due diligence and other obligations.

Customer due diligence records are generally required to be retained for seven years after the relevant business relationship ends or, in the case of an occasional transaction, for seven years after the transaction is completed. Different retention periods or starting points can apply to other types of AML/CTF records.

We retain sufficient information to demonstrate the customer due diligence undertaken and to comply with applicable legal requirements. The AML/CTF record-keeping requirements do not, merely because an identity document was used for verification, require Somners to retain a scanned or photocopied copy of that document itself.

Where a complete copy of an identity document is collected, we take reasonable steps not to retain that complete copy once it is no longer required for verification, another AML/CTF purpose or another lawful purpose. We will retain the information and records necessary to demonstrate the customer due diligence undertaken and satisfy applicable record-keeping requirements.

Keeping Information Secure

Information collected for customer due diligence can include identification information that warrants careful protection. Somners takes reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure, in accordance with our obligations under the Privacy Act 1988.

Access And Correction

You may request access to personal information Somners holds about you and may ask us to correct information that you believe is inaccurate, out of date, incomplete, irrelevant or misleading.

We may need to verify your identity before providing access to personal information. Access may also be limited or refused where an exception under applicable law applies or where providing the information would itself be prohibited by law.

Further information about access, correction, privacy complaints, information security, retention and the way Somners handles personal information generally is contained in our Privacy Policy, which is available on the Somners website.

Privacy Enquiries

If you have a question about the personal information we collect for customer due diligence, our privacy practices, or your rights in relation to personal information, please contact Somners Pty Ltd at:

Last updated: 21 August 2026