AML Compliance Guide
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AML/CTF program for Conveyancers — 2026 AUSTRAC Guide

If your conveyancing practice provides a designated service from 1 July 2026, you must have a written AML/CTF program that fits how your files, clients and settlement money actually work. For conveyancers, this matters because property transfers are a known channel for money laundering, especially where there are complex ownership structures, third-party funds, cash components or unusual instructions. If you do not comply, AUSTRAC can take enforcement action, civil penalties can reach $33.5 million per contravention, and intentional breaches can also attract criminal penalties.

Your AML/CTF obligations

  1. 1. AUSTRAC enrolment
  2. 2. Compliance officer
  3. 3. ML/TF risk assessment
  4. 4. AML/CTF program
  5. 5. Customer due diligence
  6. 6. Sanctions screening
  7. 7. Suspicious matter reporting
  8. 8. Record keeping (7 years)
  9. 9. Staff training

Your AML/CTF program is not a template you download and forget. It is a written document, approved by senior management, with two parts: first, your ML/TF risk assessment; second, the policies, procedures, systems and controls you will use to manage those risks. For a conveyancer, that means the program should deal with the real pressure points in conveyancing work: verifying clients before acting, checking who really owns or controls a company or trust buying property, screening clients against sanctions lists, spotting suspicious source-of-funds issues, handling urgent settlement instructions safely, keeping records for 7 years, and training staff who open files, collect ID or handle settlement money.

Deadline and order matter

You must complete your ML/TF risk assessment before you finalise your AML/CTF program, and the program must be finalised by 31 December 2026. If your practice starts providing a designated service after 1 July 2026, you still need the same written program and must enrol with AUSTRAC within 28 days of first providing that service.

How a conveyancing practice should build its program

  • Map your designated services first. Do not assume every matter is covered. Identify which conveyancing activities trigger the AML/CTF Act and who in your office performs them.
  • Write a conveyancing-specific risk assessment covering customer types, services, delivery channels and geography. Include higher-risk scenarios such as overseas clients, rapid on-sales, private funding arrangements, company or trust purchasers, nominee arrangements and unexplained third-party payments.
  • Set your file-opening rules. No designated service should be provided until customer identity is verified, including beneficial owners for companies and trusts.
  • Build practical controls for settlements and funds handling: escalation for last-minute changes to bank details, extra review for inconsistent source-of-funds information, and clear steps for when an SMR may be required.
  • Approve the program at owner or principal level, train everyone who deals with clients or transactions, and update the program whenever your practice changes materially.

A common mistake in conveyancing is treating the AML/CTF program as separate from file management. It should be built into your intake forms, ID check process, trust and company checklists, settlement workflow and supervision arrangements. Another mistake is assuming low-value residential matters are automatically low risk. A standard house purchase can still be suspicious if the buyer cannot explain the source of funds, the funds come from unrelated third parties, the true controller sits behind a trust structure, or the client is unusually secretive about the transaction. Another misconception is that AUSTRAC enrolment itself is enough. It is not a licence and it does not replace the program.

Practical tips for small conveyancing offices

  • Use one matter opening checklist for every property file so staff do not skip CDD when a settlement is urgent.
  • Create separate review steps for company buyers, trust buyers and attorneys acting under power of attorney, because ownership and control questions are different in each case.
  • Keep sanctions screening evidence on file and repeat screening during the relationship if the matter runs for some time or circumstances change.
  • Document who can approve higher-risk matters, such as politically exposed persons, overseas clients or unexplained third-party funding.
  • Record training attendance and version-control your program so you can show AUSTRAC when it was approved and what changed.

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Frequently asked questions

Do I need an AML/CTF program if I only do residential conveyancing for local clients?
Yes, if you provide a designated service, you need a written AML/CTF program regardless of whether your matters seem straightforward. Local residential work is not exempt. Your risk assessment may rate many files as lower risk, but you still need documented controls for identity checks, beneficial ownership, sanctions screening, suspicious matter reporting, record keeping and staff training.
Can I just use AUSTRAC’s conveyancer starter kit and leave it at that?
No. A starter kit is a useful base, especially for a small practice, but your final program must match your own services, clients, staff structure and workflow. If your office handles trust purchasers, company buyers, remote clients or settlement funds in a particular way, the program needs to reflect that.
What if I only act for the seller and never receive purchase money myself?
You still need to work out whether the service you provide is a designated service. The AML/CTF Act is triggered by designated services, not only by physically holding money. If your work falls within a designated service, your program must cover seller-side risks too, including unusual sale structures, related-party transactions and suspicious instructions.
How much will it cost a small conveyancing practice to put a program in place?
AUSTRAC enrolment is free, but creating the program will still cost time and usually some money. Common costs are staff time, ID verification tools, ASIC searches, sanctions screening, training and legal or compliance help if your matters are more complex. The cheaper option is usually to build a simple, accurate program early rather than retrofit one after files are already underway.
When do I have to update the program after it is finished?
Update it whenever your business changes materially. For a conveyancer, that could include adding new service types, opening another office, taking on interstate or overseas clients, changing your settlement process, introducing remote onboarding, or seeing new risk patterns in company or trust purchasers. Training should also be repeated when the program is updated.

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