Are buyer's agents captured by Tranche 2 even if they don't handle money?
Buyer's agents are captured because AUSTRAC treats brokering a real estate sale, purchase or transfer on behalf of a party as a designated service.
Yes - 100% captured. AUSTRAC states anyone "Brokering the sale, purchase or transfer of real estate on behalf of a buyer, seller, transferee or transferor in the course of carrying on a business". AUSTRAC considers a broker is a person who acts as an intermediary or agent for another person for consideration.
To provide this designated service you must be operating as a broker in the course of carrying on a business. A common indicator of this will be if your services include negotiating on behalf of the person you represent or seeking to find a person for the person you represent to transact with, in return for a payment of a commission. The is core service a buyer’s agent provides.
AUSTRAC
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