If your conveyancing practice will provide a designated service from 1 July 2026, you need a clearly appointed person to take carriage of AML/CTF compliance from the start. For a small conveyancing business, that usually means the principal, director or another senior person who can make decisions, keep enrolment and reporting on track, and drive the practice’s AML/CTF setup. If you miss the 29 July 2026 deadline to get your foundation obligations in place, or no one is genuinely responsible for compliance, AUSTRAC can take enforcement action and civil penalties can reach $33.5 million per contravention.
Your AML/CTF obligations
For conveyancers, a compliance officer is the person inside the practice who owns the day-to-day AML/CTF job. AUSTRAC’s guidance for newly regulated businesses puts strong emphasis on governance, oversight and practical implementation, especially for small firms. This person does not need a special licence, but they do need enough authority, time and knowledge to make sure the practice enrols with AUSTRAC, completes its ML/TF risk assessment, builds its AML/CTF program, sets up customer due diligence for buyers, sellers and related entities, and handles reporting if suspicious activity appears in a property matter.
Deadline that drives this role
Your practice must enrol with AUSTRAC by 29 July 2026 if you are providing newly regulated designated services from 1 July 2026. In a small conveyancing firm, the compliance officer should be identified before enrolment so there is one accountable person managing setup, updates to enrolment details, and the move toward a final AML/CTF program by 31 December 2026.
What a conveyancing practice should do now
A common mistake in conveyancing practices is treating this as a title only. AUSTRAC will expect the person named internally to actually run the process. Another mistake is assuming your settlement platform, law practice software, bank or real estate agent will cover AML/CTF for you. They will not. Your practice remains responsible for checking whether the service you provide is a designated service, identifying the client properly, screening against sanctions lists, and reporting suspicious matters without tipping off the client. Purely administrative delegation is not enough if no one senior is overseeing the system.
Make the role practical. The compliance officer should create one conveyancing-specific workflow covering file opening, purchaser and vendor ID verification, company and trust ownership checks, PEP and sanctions screening, source-of-funds questions where something does not stack up, and escalation when staff see red flags. For example, if a buyer wants urgent completion, uses a newly formed company, changes funding arrangements late, or sends money through unrelated third parties, staff should know exactly when to pause and escalate to the compliance officer. That is how the role protects the practice: not by adding paperwork for its own sake, but by stopping risky matters from sliding through unnoticed.
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