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Compliance

Compliance checked on every sale, not every quarter.

AML, identity checks, beneficial owners, vendor statements, agent licences and marketing consent, worked out from each deal's facts and shown where you work.

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Compliance checks on the sale of Fitzroy Espresso Pty Ltd, a share sale in Victoria for $380,000. Because it is a share sale, it is suggested as an AML designated service. The vendor's ID check and both beneficial owners are verified, then the buyer's. Goodwill and plant come to $380,000, under the $450,000 threshold, so a section 52 vendor statement is needed. The responsible agent's licence expires on 30 November. Before an email goes out, consent is checked: Tom Okafor can be emailed but has opted out of SMS.

AML

Fitzroy Espresso Pty Ltd · share sale

Designated service
Sale typeShare sale
Deposit heldIn trust
Vendor IDVerified
Buyer IDDue

Suggested because it's a share sale

Tranche 2 AML, on the deal

From 1 July 2026, some business sales bring brokers under Australia's AML/CTF regime. Batonford suggests when a sale is likely to be a designated service and why.

  • Suggested when it's a share sale or you hold the buyer's deposit in trust
  • Override the suggestion either way, with the decision recorded
  • UK firms get the same check under MLR 2017
  • Your AML program and reporting stay with your firm
A broker on a phone call at her laptop in a bright office

ID check passed

Dana Whitfield · review in 2028

ID checks and beneficial owners

Record who was checked, how and when the check is due for review. A person or company counts as verified only while their latest check stands.

  • Checks on vendors, buyers and the companies behind them
  • Beneficial owners recorded for company parties
  • A reminder 30 days before a check is due for review
  • Contacts can't be anonymised while their checks are inside the retention period

Victoria · s52

Fitzroy Espresso

Statement needed
Goodwill$310,000
Plant and equipment$70,000
Total$380,000
Threshold$450,000

Vendor statements and licences

In Victoria, a business sold for A$450,000 or less (goodwill plus plant) needs a section 52 vendor statement. Batonford checks every Victorian listing.

  • The s52 test run on goodwill and plant, without stock or real estate
  • Each broker's licence and expiry date on file
  • A reminder 30 days before a licence expires
  • New Zealand licences checked too. Elsewhere, expired licences are flagged.

Consent · Tom Okafor

Australia · Spam Act

Email OK
EmailExpress · 2 Mar 2026
SMSOpted out · 9 Sep 2026
PhoneInferred · enquiry

Consent before contact

Every contact has a ledger of consent and opt-outs per channel. The latest entry decides, and the rules follow the contact's country.

  • Australia's Spam Act and New Zealand's UEMA: express or inferred consent
  • Canada's CASL: implied consent that lapses, with a reminder before it does
  • UK PECR, Irish ePrivacy and US CAN-SPAM and TCPA
  • An unsubscribe recorded and honoured on every channel it covers

You make the call

Every suggestion shows its reason and can be overridden.

On the card

Warnings show on the listing, not in a report you forget to run.

Records kept

History stays through the AML retention period.

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