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The Customer Is Both the Seller and the Buyer: Real Estate's Least Expected CDD Rule

AUSTRAC is blunt: broker a property sale and the customer is both the seller and the buyer. You must run initial CDD on the side you do not act for. The workable part is the clock: 28 days after exchange of contracts, or 3 days before the initially agreed settlement day, whichever comes first. Here is the rule, the auction scenario AUSTRAC itself walks through, and what to do when the other side will not cooperate.

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