AUSTRAC's Tranche 2 requirement is a single verified identity check, not 100 points. However, some state real estate licensing bodies also require a separate 100-point VOI (Verification of Identity) check. Workflow's combined VOI + AML option satisfies both in a single process.
What is KYC?
KYC stands for Know Your Customer. It is the identity verification required under the AML/CTF Act. It confirms that the person is who they say they are, using a government-issued identity document verified against a trusted source.
AUSTRAC requires one successful identity check. There is no 100-point threshold under AML law.
What is 100-point ID?
The 100-point system comes from a different regulatory framework. It's a score-based check where different identity documents are assigned point values. For example, a passport is worth 70 points, a driver licence 40 points, and so on. Reaching 100 points satisfies the check.
Some state real estate regulators still require 100-point VOI checks as a condition of your licence, separate from the AML obligation.
So do I need both?
Possibly, and the answer depends on your state's licensing requirements. Here's how it breaks down:
Obligation | What's required | Why |
AML/CTF (AUSTRAC) | Single verified identity document | Federal law — applies nationally from 1 July 2026 |
VOI (state licensing body) | 100-point check (in some states) | State-based requirement — varies by jurisdiction |
If you're in a state that requires 100-point VOI, running two separate processes creates double handling and a worse client experience.
The combined VOI + AML option in Workflow
Workflow offers a combined VOI + AML verification that satisfies both obligations in a single check. When you select this option:
Your client completes the standard identity verification through Workflow
Workflow captures the documents needed to satisfy both the AML check and the 100-point VOI threshold
A single report is generated that covers both requirements
You don't need to run a separate 100-point check, the combined option handles it.
Which option should I choose?
For most real estate agents in Australia: You can use the KYC + AML option unless you are aware of explicit rules requiring you to complete the VOI + AML 100 point ID check.
If you operate as a buyer's agent or in a capacity where no state VOI obligation applies, the standard AML verification is sufficient.
If you're unsure which applies to your licence, check with your state real estate institute or licensing body.
What about legal professionals?
Legal professionals (conveyancers and solicitors) have their own professional body requirements around client verification. Workflow's verification options also cater to these obligations. We recommend speaking to your professional association to confirm what's required in your jurisdiction.
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This article provides general information only and is not legal advice.