AML Compliance for Conveyancers: What AUSTRAC Expects From 1 July 2026

If you're a conveyancer in Australia, you're now regulated under the AML/CTF regime. AUSTRAC enrolment opened on 31 March 2026, and full obligations begin 1 July 2026. Here's everything you need to know.

Conveyancers Are a Separate Category

AUSTRAC treats conveyancers as a distinct sector from real estate agents and from legal practitioners. Even if you hold a legal practising certificate, if your primary work is conveyancing, the conveyancer-specific guidance applies to you.

This matters because:

• AUSTRAC has published a dedicated conveyancer starter kit with tailored templates
• Your risk profile differs from both real estate agents and lawyers
• The designated services that trigger your obligations are specific to conveyancing work

Who Needs to Comply?

You are covered if you provide conveyancing services as defined under the reformed AML/CTF Act. This includes:

• Transferring or facilitating the transfer of real property — acting on behalf of a buyer or seller in a property transaction
• Managing client money in connection with property transactions — holding deposits, managing settlement funds in trust
• Creating or managing legal structures related to property — e.g., setting up a trust to hold property

Who is the AUSTRAC Conveyancer Starter Kit Designed For?

AUSTRAC's starter kit is specifically designed for small conveyancing practices with:

• 15 or fewer personnel
• Non-practising lawyers (or those whose primary work is conveyancing)
• Mostly individual Australian resident clients
• Services limited to standard residential and commercial conveyancing

If your practice is larger or more complex, you'll need to expand beyond the starter kit.

Key Deadlines

Important: Enrolment is already open. Don't wait until July — start now so you're ready when obligations kick in.

Your 6-Step Compliance Roadmap

Step 1: Enrol with AUSTRAC

Go to AUSTRAC Online and create an account. You'll need:

• Your ABN and business details
• Details of your designated services
• Compliance officer name and contact information
• Beneficial ownership details (if applicable)

Most conveyancers only need to enrol (not register). Registration is only required if you provide remittance or virtual asset services.

Step 2: Develop Your AML/CTF Program

Your program must cover Part A through Part F:

AUSTRAC's conveyancer starter kit provides templates for each part. AML Mate uses these official templates to generate your program in minutes.

Step 3: Conduct a Risk Assessment

Before you can finalise your program, you must assess the ML/TF risks your practice faces. Consider:

• Customer risk: Do you act for overseas buyers? Corporate structures? Trusts with complex ownership?
• Service risk: Do you handle high-value transactions? Commercial property? Off-the-plan sales?
• Geographic risk: Are transactions in areas with high property fraud risk? Any connection to FATF high-risk jurisdictions (North Korea, Iran, Myanmar)?
• Channel risk: Do you accept instructions remotely? Are clients referred by unknown third parties?

Your risk assessment determines how rigorous your CDD procedures need to be. Higher risk = more checks.

Step 4: Implement Customer Due Diligence (CDD)

CDD is the core of your compliance obligations. For every client:

Initial CDD (before providing services):

• Verify their identity using government-issued photo ID
• For companies: identify beneficial owners (anyone who owns or controls 25%+ of the entity)
• For trusts: identify the trustee, settlor, and beneficiaries
• Assign a risk rating (low, medium, or high)
• Screen against the DFAT sanctions list and check for Politically Exposed Persons (PEPs)

Ongoing CDD:

• Monitor the client relationship for changes
• Update CDD information when trigger events occur (e.g., change in ownership, unusual transaction patterns)
• Conduct periodic reviews based on risk level

Enhanced CDD (for high-risk clients):

• Obtain additional source of funds/wealth documentation
• Conduct more detailed background research
• Obtain senior management approval for the relationship
• Monitor more frequently

Transitional rule: For existing clients as of 1 July 2026, you have until 30 March 2029 to complete initial CDD. But you must still assess and manage their ML/TF risk during this period.

Step 5: Know Your Reporting Obligations

As a reporting entity, you must file reports with AUSTRAC:

• Suspicious Matter Reports (SMRs): If you form a suspicion about ML/TF, you must file within 3 business days (or 24 hours for terrorism financing). You cannot tip off the client.
• Threshold Transaction Reports (TTRs): If you receive $10,000 or more in cash in a single transaction, you must report within 10 business days.
• Annual Compliance Report: A self-assessment submitted to AUSTRAC each year.

Step 6: Train Your Staff

Every person involved in providing designated services must receive AML/CTF training covering:

• The basics of money laundering and terrorism financing
• Your practice's AML/CTF program
• How to identify suspicious activity in conveyancing
• Internal escalation and reporting procedures
• Record keeping obligations

Training must be completed within 30 days of starting and refreshed annually.

Red Flags for Conveyancers

Watch for these suspicious indicators in your day-to-day work:

• Client is reluctant to provide identification or provides unusual documents
• Unexplained urgency to complete a transaction
• Purchase price significantly above or below market value
• Funds coming from an unrelated third party with no clear explanation
• Client asks you to hold or transfer funds that aren't connected to a property transaction
• Structuring deposits to avoid the $10,000 cash reporting threshold
• Multiple properties purchased in quick succession by the same buyer (or related parties)
• Requests to send settlement funds to an overseas account
• Nominee purchases where the true buyer is concealed behind a corporate structure
• Client is based in or has connections to a FATF high-risk jurisdiction

If you see these patterns, you may need to file an SMR. When in doubt, report — AUSTRAC would rather receive an unnecessary report than miss a suspicious transaction.

Penalties for Non-Compliance

AUSTRAC takes enforcement seriously. Recent penalties include:

Penalties apply to businesses of all sizes. In 2024 alone, AUSTRAC issued 14 infringement notices to various entities. Failing to enrol is itself an offence, with daily penalties for non-compliance.

For Tranche 2 entities, fines can reach up to $31.3 million for firms and $6.26 million for individuals.

What AUSTRAC Expects

AUSTRAC has been clear about their approach:

"We don't expect perfection on day one, but we do expect sustained effort, strong leadership, and genuine progress." — Brendan Thomas, AUSTRAC CEO

If you can't meet all obligations by 1 July 2026, AUSTRAC expects you to have a documented implementation plan that shows:

1. How you'll continue to manage ML/TF risks during the transition
2. The gaps between your current state and full compliance
3. A timeline for addressing those gaps
4. Who is accountable for each step

How AML Mate Helps Conveyancers

Building a compliant AML/CTF program from scratch takes weeks of reading AUSTRAC guidance and drafting documents. AML Mate generates your complete program using AUSTRAC's official conveyancer starter kit templates:

• AML/CTF Program (Part A-F) tailored to conveyancing — generated in 15 minutes
• Risk assessment based on your specific practice profile
• Client management with built-in CDD workflows and risk scoring
• Sanctions and PEP screening — automatic checks against DFAT and international databases
• SMR and TTR forms — guided reporting with pre-filled fields
• Training modules — 5 AML/CTF modules with quizzes and certificates for your staff
• AI compliance assistant — ask questions about your obligations anytime, powered by AUSTRAC's official guidance

Ready to start? Run a free compliance check to see where your practice stands, or view pricing to get your full AML/CTF program today.