No — AML and KYC checks in Workflow are for your clients (buyers, sellers, vendors, and other parties to a transaction), not for your own employees or sales team.
Who AML checks are for
Under the AML/CTF Act, Customer Due Diligence (CDD) applies to the people you provide a designated service to — your clients. This means:
Buyers and sellers involved in a property transaction
Vendors on a listing
Individuals or entities entering a legal retainer (for legal firms)
Your own staff, agents, and team members are not clients under the Act and do not need to be run through Workflow.
What about staff background checks or licence verification?
Employment screening — such as police checks, licence verification, or right-to-work checks — is separate from AML compliance and is not handled by Workflow. These requirements sit under employment law and real estate licensing regulations, not the AML/CTF Act.
Do agents still need to do AML training?
Yes — while agents do not need to be checked as clients, they do need to complete AML training. AUSTRAC requires that staff involved in AML/CTF compliance are adequately trained. See APLYAcademy in your Workflow account for mandatory modules.
This article provides general guidance only and is not legal advice.
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