For Conveyancers

AML/CTF program for conveyancers in Australia — AUSTRAC Tranche 2 from July 2026

Conveyancing is one of the most exposed Tranche 2 services — every settlement is in scope, every party needs CDD, and trust-account inflows over $10,000 in cash trigger threshold reporting.

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Compliance Challenges for Conveyancers

Every property settlement is a designated service from 1 July 2026. AutoAML drafts a conveyancing-specific AML/CTF program with CDD scripts and TTR procedures.

Every settlement is in scope — there's no de minimis

Unlike some sectors with carve-outs for low-value work, every property transfer you act on is a designated service. Your program needs to handle high-volume CDD without strangling settlement timelines.

Trust-account inflows are a TTR trigger

Cash or cash-equivalent deposits of $10,000 or more to your trust account require a Threshold Transaction Report (s 43) within 10 business days. Multiple smaller deposits across a single matter that look like structuring must also be considered for an SMR.

Identity verification before settlement, not at it

VOI under your state's e-conveyancing rules is necessary but not sufficient. AUSTRAC's CDD requirements include source-of-funds inquiries and beneficial-ownership look-through that VOI doesn't cover.

Sole practitioners and small firms still need a Compliance Officer

The Act does not exempt small firms from the Compliance Officer role. You can hold the role yourself, but you still need to document the appointment, the responsibilities, and how independent review will work.

What Conveyancers Need for Compliance

The AML/CTF Act 2006 (Cth) and the AML/CTF Rules require all reporting entities to maintain these documents and procedures.

AML/CTF Program with Part A and Part B sections — s 81 of the Act

ML/TF Risk Assessment for property transfer and settlement services

CDD procedures for buyers, sellers, beneficial owners and authorised representatives

Trust-account transaction-monitoring rules

TTR procedure for $10,000+ cash equivalents (s 43)

SMR workflow for structured deposits and unusual settlement patterns

Source-of-funds inquiry script for high-risk matters

7-year record retention covering CDD evidence and transaction logs (s 107)

Deadline & Applicability

Licensed conveyancers in all Australian states and territories become reporting entities on 1 July 2026 under the AML/CTF Amendment Act 2024. State licensing bodies are expected to issue companion guidance during 2025–2026.

Last reviewed: 18 April 2026 · Information is general guidance, not legal advice.

How AutoAML Helps Conveyancers

AI-Generated Documents

All 13 compliance documents drafted from your service mix and risk profile — Part A, Part B, risk assessment, CDD scripts, the lot.

Team & Audit Trail

Invite your team, assign Compliance Officer roles, and keep a tamper-evident audit log AUSTRAC supervisors can read.

SMR & TTR Built-in

Reporting workflows, training tracking, annual review reminders and document version control — so the program stays alive after day one.

Frequently Asked Questions

Conveyancers & AUSTRAC: common questions

Do small conveyancing practices need the same program as large firms?

Yes, but proportionate. The Act's program requirements are the same; the depth of risk assessment, the volume of CDD records, and the scale of monitoring scale to your practice. AutoAML's draft is sized to a 1–10-person practice by default.

How does this interact with state e-conveyancing VOI rules?

VOI satisfies your land-titles obligations on identity but does not satisfy AUSTRAC's full CDD requirements — particularly source of funds, beneficial ownership of trust and corporate buyers, and PEP/sanctions screening. You need both, and the records they generate live in different files.

What do we do when funds arrive from an unexpected third party?

Your CDD should require a source-of-funds explanation before settlement. If the explanation is unconvincing or refused, your Part B procedures should escalate to the Compliance Officer for an SMR consideration. Don't proceed with settlement until the matter is resolved.

Do we need to report every $10,000+ deposit?

Only physical-currency or cash-equivalent transactions of $10,000 or more trigger a TTR. Bank transfers between regulated institutions don't, but they are still subject to your transaction-monitoring rules and may warrant an SMR if they look unusual.

Who is liable if a paralegal misses a red flag?

The reporting entity (the firm) is liable. That's why staff training, escalation paths and clear desk procedures are explicit Part A requirements — supervision failures are pursued by AUSTRAC, not just the individual error.

How often does the program need to be reviewed?

Annually at a minimum, plus on any material change to services, ownership or risk environment. Independent review is also required and cannot be conducted by the same person who runs day-to-day compliance.

Related industries under AUSTRAC Tranche 2

Many firms work across more than one designated-service category. Check the related sectors below.

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