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How To Meet AML/CTF Requirements For Conveyancers Australia

How To Meet AML/CTF Requirements For Conveyancers Australia

Australia’s Tranche 2 AML/CTF reforms are no longer a distant policy discussion, they’re arriving in just over two months. From 1 July 2026, conveyancers will be required to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act, bringing the profession under AUSTRAC’s regulatory oversight for the first time. If you haven’t started preparing, the window is closing fast. Understanding the full scope of AML/CTF requirements for conveyancers Australia is the first step toward being ready.

The obligations are significant. You’ll need to register with AUSTRAC, build a compliant AML/CTF program, conduct customer due diligence (including identity verification), and establish ongoing transaction monitoring and reporting processes. For many practices, this represents a fundamental shift in how client onboarding works, and doing it manually or with disconnected tools creates real compliance risk.

This guide breaks down exactly what’s required of conveyancers under the new regime, the key deadlines you need to hit, and practical steps to build your compliance program. We’ll also cover how StackGo’s IdentityCheck integration helps conveyancers run KYC/AML identity verification directly from their existing CRM, no new software to learn, no compliance gaps from copying data between systems.

What changed and who is in scope

Australia’s AML/CTF legislation changed significantly when the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 received royal assent. Until that point, only banks, remittance dealers, and similar financial institutions were required to register with AUSTRAC and operate a compliance program. The 2024 reforms extend those obligations to a wide range of professional services providers, including conveyancers, as part of Australia’s commitment to meet Financial Action Task Force (FATF) recommendations and close the gaps that make property transactions a known vehicle for money laundering.

What the Tranche 2 reforms actually cover

The amendment brings a group of professionals known as designated non-financial businesses and professions (DNFBPs) under the Act for the first time. If you provide a "designated service" connected to real property transactions, you become a reporting entity under the legislation. That status carries real obligations: registering with AUSTRAC, building a risk-based AML/CTF program, conducting customer due diligence, maintaining records, and filing suspicious matter reports when required.

The AML/CTF requirements for conveyancers Australia take full effect from 1 July 2026, meaning your registration and program must be operational before that date, not on it.

Which conveyancing services trigger your obligations

Not every task in your practice brings you into scope automatically. The obligations attach to specific designated services. You are in scope if you provide any of the following on behalf of a client:

Which conveyancing services trigger your obligations

Designated service Example
Buying or selling real property Acting on a residential or commercial property purchase
Transferring ownership Processing a title transfer, including subdivisions
Settlement involving movement of funds Handling or arranging the receipt or disbursement of settlement funds

If your practice handles any of these services, compliance is mandatory regardless of practice size. A sole trader completing a single residential transfer is just as much in scope as a large multi-partner firm settling hundreds of transactions per year.

Step 1. Confirm scope and enrol with AUSTRAC

Meeting the AML/CTF requirements for conveyancers Australia starts with confirming you are in scope. If you provide any of the designated services listed in the previous section, you are a reporting entity and must register with AUSTRAC before 1 July 2026. Operating as a reporting entity without registration is a breach of the Act, regardless of practice size.

How to register with AUSTRAC

Registration is completed through AUSTRAC Online, the regulator’s secure portal. You will need accurate details about your business structure, the services you provide, and your beneficial owners and principal officers. Allow at least 30 minutes to complete the process without interruption.

Register early. AUSTRAC Online can slow during high-volume periods close to the deadline, and a last-minute technical issue will not excuse a missed registration.

Gather these details before you start:

  • ABN and legal business name
  • Business address and contact details
  • Designated services your practice provides
  • Beneficial owner names, dates of birth, and addresses
  • Principal officer details

After you register

AUSTRAC assigns your practice a reporting entity registration number once registration is complete. Store this number where your compliance officer and admin staff can access it quickly, since you will reference it across suspicious matter reports and all future AUSTRAC filings.

Keep your registration current. If your services or business structure change, update AUSTRAC Online immediately, as outdated registration details are a compliance risk in their own right.

Step 2. Build your AML/CTF program and risk assessment

Once registered, your next obligation under the AML/CTF requirements for conveyancers Australia is to build and maintain a written compliance program. The program must be risk-based, meaning the controls you put in place should reflect the actual money laundering and terrorism financing risks your practice faces, not a generic template lifted from another industry.

What your AML/CTF program must contain

Your program needs to address four core parts under the Act. Each part must be documented and kept current as your services or client base evolves.

Program part What it covers
Part A: AML/CTF risk assessment Identifying and assessing risks across your clients, services, and geographies
Part B: Customer due diligence Procedures for identifying and verifying clients before settlement
Part C: Ongoing monitoring Transaction monitoring and updating client information over time
Part D: AUSTRAC reporting Suspicious matter reports and threshold transaction reports

How to complete your risk assessment

The risk assessment is the foundation the rest of your program sits on. Work through each designated service you provide and score risk across three dimensions: client type (individual, company, trust), transaction type (purchase, transfer, refinance), and geography (domestic versus international funds).

A risk assessment completed by one person in isolation is easy to miss gaps in. Involve your senior settlement staff when scoring client and transaction risk categories.

Document your scoring rationale in writing. AUSTRAC expects you to demonstrate why you assigned each risk rating, not just what it is.

Step 3. Set up CDD, screening, and record keeping

Customer due diligence is where the AML/CTF requirements for conveyancers Australia become operational. You must verify each client’s identity before you act on their behalf, and your procedures need to match the risk level you assigned in your risk assessment.

What CDD must include

Your CDD process must collect and verify the following for individual clients before settlement:

What CDD must include

  • Full legal name confirmed against a primary identity document
  • Date of birth and residential address confirmed against a secondary document
  • Beneficial ownership details for companies and trusts, including the identity of controlling persons

If a client refuses to provide identity documents before settlement, treat that refusal as a red flag and assess whether a suspicious matter report is required.

Screening and record keeping

Run each client against sanctions lists and politically exposed person (PEP) databases at onboarding and again immediately before settlement. A digital verification tool connected to your existing CRM can automate both checks and write the outcome directly into the client file, removing the risk of missed steps between systems.

Keep all CDD documents, screening results, and transaction records for seven years after the relationship ends. Store them in a format that is retrievable quickly if AUSTRAC requests access. A paper-based system is a compliance liability at this volume, so move records into a structured digital system before your go-live date.

Step 4. Train staff and run go-live checks

Your compliance program is only as strong as the people running it. Before your go-live date, every staff member who touches client onboarding, identity verification, or transaction processing must understand their responsibilities under the AML/CTF requirements for conveyancers Australia.

Build a staff training record

Training needs to be documented and repeatable, not a verbal briefing delivered the week before the deadline. Cover the following topics in at least one structured session and keep a written record of who attended and when:

  • What AML/CTF obligations apply to your practice
  • How to collect and verify client identity documents
  • When to escalate a red flag to your compliance officer
  • How to complete a suspicious matter report
  • Your record-keeping and retention obligations

Retain signed training records for each staff member. AUSTRAC may request evidence that your team received formal training if your practice is reviewed.

Complete a go-live readiness check

Run through this checklist in the week before 1 July 2026 to confirm your practice is operationally ready before the deadline hits:

Check Done
AUSTRAC registration complete and number stored
Written AML/CTF program finalised and approved
CDD procedures tested on a real client file
Screening tool connected to your CRM
Staff training records signed and filed

Treat any unchecked item as a priority action and assign a named staff member to close it before go-live.

aml/ctf requirements for conveyancers australia infographic

Your next steps before 1 July 2026

The deadline is fixed. Meeting the AML/CTF requirements for conveyancers Australia before 1 July 2026 requires action now, not in June. Work through each step in this guide in order: confirm your scope, register with AUSTRAC, build your written program, implement CDD and screening, and train your team. Each step depends on the one before it, so starting late compresses your testing time and increases your risk of gaps on go-live day.

Manually collecting documents, running sanctions checks, and copying results into client files takes far longer than expected at scale and introduces compliance errors. StackGo’s IdentityCheck runs KYC/AML verification directly inside your existing CRM, writing outcomes back to the client file automatically, so your team never works across disconnected systems. See how IdentityCheck supports your Tranche 2 compliance and create a free account to test it against your current onboarding workflow.

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