AML Compliance Guide
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Staff training for Conveyancers — 2026 AUSTRAC Guide

If your conveyancing practice provides a designated service from 1 July 2026, you must train the people who open files, verify clients, receive or move trust money, prepare settlement documents, or spot suspicious activity. For conveyancers, training is not a box-ticking exercise: it is how your staff apply customer due diligence, sanctions screening, suspicious matter reporting and record keeping correctly in property matters. If you do not train relevant staff and keep evidence of that training, AUSTRAC can take enforcement action, civil penalties can reach $33.5 million per contravention, and intentional breaches can carry 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

For a conveyancing practice, staff training must be tailored to how property transactions actually run in your office. That means training should cover when AML/CTF checks happen in a sale, purchase or transfer matter; what ID documents are acceptable; how to identify the real client where a company or trust is buying property; when a politically exposed person needs enhanced due diligence; how to screen clients against DFAT and UN sanctions lists; what unusual settlement instructions look like; and how to escalate concerns without tipping off the client. AUSTRAC expects training to match the person’s role, the ML/TF risks they handle, and your own AML/CTF policies and procedures.

What a conveyancing principal should do

  • Map the roles in your practice that touch AML/CTF obligations: reception taking onboarding documents, paralegals opening matters, conveyancers verifying clients, trust account staff handling funds, and the principal or manager approving higher-risk matters.
  • Decide what each role needs to know. A junior administrator may need basic awareness and escalation training, while the person checking source of funds or unusual settlement changes needs deeper training.
  • Write training into your AML/CTF program and link it to your ML/TF risk assessment, so the content reflects the property work you actually do.
  • Deliver initial training before staff perform AML/CTF-related functions, then refresher training on a documented schedule and whenever your program, risks or the law change.
  • Keep records that show who was trained, when, on what content version, how training was delivered, and whether the person understood it.

AUSTRAC’s expectation on frequency

AUSTRAC guidance says AML/CTF compliance officers and senior management should receive training every 6–12 months. Customer-facing personnel and personnel responsible for onboarding, transaction monitoring or enhanced CDD should receive training every 12 months. If your policies change, new property-related ML/TF risks emerge, or AUSTRAC issues new guidance, update training as soon as practicable.

A common mistake in conveyancing practices is assuming a generic online course is enough. It is not. AUSTRAC says its e-learning and third-party training can help, but cannot be relied on solely because your training must be tailored to your business, your risks and each person’s role. Another common mistake is training only fee earners and forgetting support staff. If your receptionist collects ID, your accounts person receives deposit instructions, or your assistant notices a last-minute change to where sale proceeds are sent, they need training relevant to those tasks.

Practical training topics for conveyancing matters

  • How to verify individuals, companies and trusts involved in property purchases, transfers and settlements
  • How to identify beneficial owners where the buyer or seller is a company, family trust or nominee arrangement
  • Red flags such as unexplained third-party payments, urgency around settlement, complex ownership structures, repeated changes to parties, or inconsistent source-of-funds explanations
  • When to escalate a matter for enhanced due diligence, including PEPs, high-risk countries and unusual cash proposals
  • How to file internal escalations, preserve records for 7 years after the relationship ends, and avoid tipping off if an SMR is being considered

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Frequently asked questions

Do I need to train every person in my conveyancing practice, or only licensed conveyancers?
You must train all staff who deal with customers or handle relevant transactions, and anyone else performing AML/CTF-related functions. In a conveyancing office, that often includes administrative staff, paralegals, trust account staff and principals, not just the licensed conveyancer handling the file. Staff with no AML/CTF role still need at least basic awareness at onboarding if your business policies assign them any support responsibilities.
Can I just use AUSTRAC’s online modules and keep costs down?
You can use AUSTRAC e-learning as part of your training, but not as the whole solution. AUSTRAC says training must be tailored to the person’s AML/CTF functions, the ML/TF risks relevant to their role, and your own AML/CTF policies. For a conveyancing practice, that usually means adding role-specific examples from property files, settlements and trust money handling.
What if I have one part-time assistant who only collects ID documents and books appointments?
That assistant still needs training before doing AML/CTF-related work. The training can be lighter than the principal’s training, but it must cover what documents to collect, what inconsistencies to spot, when to escalate concerns, and what not to say to a client if something looks suspicious. Keep a training record showing what was covered and when.
How do I handle training when procedures change after we finalise our AML/CTF program?
Update training as soon as practicable when your AML/CTF program changes, when your ML/TF risks change materially, or when AUSTRAC guidance highlights a gap. Do not wait for the next annual refresher if the change affects onboarding, sanctions screening, enhanced due diligence or settlement funds handling. Record the updated training content, who received it and any follow-up needed.
What if a staff member fails the training or still does not follow the procedure correctly?
Provide targeted follow-up or remedial training tailored to the issue, then reassess understanding through testing, observation or manager sign-off. AUSTRAC guidance also points to documenting the action taken, dates and results. If the person still cannot meet AML/CTF expectations, you should consider reassigning their AML/CTF functions or increasing supervision.

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