Australian conveyancers have AML/CTF obligations when they provide a designated service with the required geographical link to Australia. The new obligations started on 1 July 2026. Build the checks into client intake, handling funds and settlement, then keep evidence of the decisions you make.
Conveyancers Are a Separate Category
Choose guidance that matches your practice, rather than relying on your job title alone.
| Your practice | Where to start |
|---|---|
| Conveyancer who is not a practising lawyer | Check every suitability condition for AUSTRAC's conveyancer starter kit. |
| Lawyer operating under a practising certificate | Use the legal profession starter kit, even when you do conveyancing work. |
| Practice outside the starter kit's suitability conditions | Develop a program that addresses your actual services and risks. |
Read the official conveyancer starter kit suitability criteria. Practising lawyers can also use our legal profession guide.
Who Needs to Comply?
Check the statutory service definitions against the work you actually do. Relevant work can include:
- Assisting a person with buying, selling or transferring real estate.
- Managing client money, accounts or assets where the designated service definition applies.
- Helping create, operate or manage companies, trusts or other legal arrangements.
General advice alone is different from actively advancing a transaction. For property transaction assistance, identify the person you assist as your customer; do not automatically treat both parties as your customers. See AUSTRAC's professional services guidance.
Who is the AUSTRAC Conveyancer Starter Kit Designed For?
The kit has specific limits, including 15 or fewer personnel, no practising lawyers, mostly Australian individual clients and a limited range of transaction assistance services. Restrictions also cover high risk clients, overseas property, client funds, fully remote self-service, selling your own property, acquiring another business and reporting group arrangements.
Check all the official suitability conditions before using it. A short checklist cannot establish that your practice qualifies.
Key Deadlines
| Date or event | What it means |
|---|---|
| 31 March 2026 | Enrolment opened for newly regulated businesses. |
| 1 July 2026 | AML/CTF obligations started for newly regulated designated services. |
| 29 July 2026 | Enrolment deadline for businesses providing those services from 1 July. This was not a general registration deadline. |
| Starting designated services later | Enrol within 28 days after the day you start providing the service. |
| Eligible pre-commencement customers | Check the specific initial CDD trigger rules, rather than assuming every existing customer needs immediate re-verification. |
These commencement dates have passed. If you have a gap, address it promptly and record the actions and responsible person. Read AUSTRAC's enrolment requirements, our existing customer CDD guide and the transitional rules guide.
Your 6-Step Compliance Roadmap
Work through these six areas and keep a record of the decisions and actions for your practice.
Step 1: Enrol with AUSTRAC
Prepare your business identifiers, designated service details and responsible contacts. Open AUSTRAC Online and follow our illustrated enrolment tutorial.
Conveyancing generally requires enrolment. Additional registration requirements apply to remittance and virtual asset services. Check your full service mix against AUSTRAC's requirements, and keep your enrolment information current.
Step 2: Develop Your AML/CTF Program
Document your risk assessment and the policies, procedures, systems and controls your practice will use. Assign responsibilities, obtain the required approval, implement the program and review it as your risks change.
AML Mate organises program content into Parts A-F. Those are product headings, not mandatory AUSTRAC section names. Your program needs to meet the substantive requirements and reflect what your practice actually does.
Use AUSTRAC's program guidance. If eligible for the starter kit, follow its customisation instructions.
Step 3: Conduct a Risk Assessment
Assess the money laundering and terrorism financing risks before finalising your controls. Record your reasoning, not just a risk score.
| Risk area | Questions for your practice |
|---|---|
| Customers | Who is behind the buyer, company or trust? Is ownership or the purpose unclear? |
| Services | Do you handle client funds or complex transactions? How could those services be misused? |
| Delivery channels | How do you verify remote instructions and third-party introductions? |
| Countries | Where are customers, funds and counterparties connected? What current country risks apply? |
Revisit the assessment when services, customers or risks change. See AUSTRAC's risk assessment guidance.
Step 4: Implement Customer Due Diligence (CDD)
Complete initial CDD before providing the designated service unless a specific exception applies. Establish the customer's identity, the purpose of the relationship, relevant representatives and beneficial owners, and the customer's risk. Use reliable, independent verification appropriate to the requirements and risk; photo ID is not the only possible method.
For beneficial ownership, 25% or more ownership and control are separate tests. A person may control an entity without owning that percentage. Read AUSTRAC's beneficial ownership guidance.
- Ongoing CDD: monitor activity and keep relevant information current throughout the relationship.
- Enhanced CDD: apply the additional measures required for higher risk situations, including relevant source of funds or wealth checks.
- Existing customers: check eligibility and triggers under the pre-commencement customer rules. An exception to initial CDD does not remove ongoing monitoring obligations.
See AUSTRAC's initial CDD requirements and enhanced CDD guidance.
Step 5: Know Your Reporting Obligations
Keep an internal escalation process so the right person can assess the facts and record the decision promptly.
| Report | Trigger and timing |
|---|---|
| Suspicious matter report (SMR) | Where the reporting conditions are met: within 24 hours of forming a terrorism financing suspicion, or within 3 business days after the day a suspicion about another matter is formed. |
| Threshold transaction report (TTR) | A transaction involving physical currency of A$10,000 or more, or its foreign equivalent, in connection with a designated service. Lodge within 10 business days after the transaction day. A bank transfer is not physical currency. |
| Compliance report | Check whether you must report or an exemption applies. The next reporting period is 1 July 2026 to 30 June 2027, with submission from 1 July to 30 September 2027. |
See the official SMR, TTR and compliance report guidance. Legal professional privilege and tipping-off rules need particular care; our SMR guide explains the relevant boundaries.
Ready to submit? Follow the illustrated tutorials to lodge an SMR, lodge a TTR or complete a compliance report. Preparing a report in AML Mate does not submit it to AUSTRAC. Keep the submission receipt with your records.
Step 6: Train Your Staff
Provide initial AML/CTF training at the start of employment or engagement, then ongoing training tailored to each person's role, responsibilities and risks. Train people before they take on new duties that require different knowledge.
Cover your program, customer checks, suspicious activity, escalation, reporting and record keeping. Assess understanding and retain completion records. Set the frequency using your risk assessment and staff needs, rather than assuming an annual session meets every need.
Read AUSTRAC's personnel training guidance.
Red Flags for Conveyancers
Look at the context and combinations of indicators:
- Ownership: concealed buyers, unexplained nominees or an unnecessarily complex company or trust structure.
- Funding: unexplained third-party payments, requests to move unrelated funds, or an unclear source of funds.
- Transaction behaviour: unusual urgency, unexplained price differences or repeated purchases inconsistent with the customer's profile.
- Payment patterns: cash structuring or overseas payment instructions that do not fit the stated transaction.
An indicator is not proof of wrongdoing or an automatic SMR requirement. Ask appropriate questions, document your assessment and escalate promptly when the reporting conditions may be met. Refer to AUSTRAC's risks and indicators guidance.
Penalties for Non-Compliance
AUSTRAC has a range of enforcement tools, including infringement notices, enforceable undertakings and civil penalty proceedings. The applicable consequences depend on the obligation and circumstances. Keep evidence that your controls operate, rather than relying on having a program document alone. Read AUSTRAC's enforcement approach.
What AUSTRAC Expects
Identify gaps, explain how you are managing the risks, assign responsible people and track corrective actions. An implementation plan does not suspend your legal obligations. See AUSTRAC's May 2026 statement of expectations.
How AML Mate Helps Conveyancers
AML Mate helps organise your program, risk assessment, client CDD records, sanctions and PEP screening, report preparation and staff training. Its legal industry option includes lawyers and conveyancers. Review the output against your services and risks; software does not replace your practice's responsibility for compliance.
Run a free compliance check to assess your starting point, or view pricing. Use the AUSTRAC Online tutorials when you are ready to submit information to the regulator.
Resources and Sources
Sources checked: 14 October 2026. This guide provides general information, not legal or compliance advice.