AML/CTF Compliance for Conveyancers
Australia's Tranche 2 reforms make conveyancers reporting entities under the AML/CTF Act for the first time. If you assist in property transfers or manage settlement funds, you have obligations to AUSTRAC. Enrolment deadline: 31 March 2026. Full compliance: 1 July 2026.
Key compliance deadlines
31 March 2026
AUSTRAC enrolment deadline for all Tranche 2 entities including conveyancers providing designated services
1 July 2026
Full compliance required — AML/CTF program, KYC, settlement fund monitoring, and AUSTRAC reporting all in effect
Contents
- 01Why conveyancers are now reporting entities
- 02Which conveyancing services are designated services
- 03Your six core AML/CTF obligations
- 04Red flags in property settlement
- 05How IntelliCompli helps conveyancers comply
- 06Frequently asked questions
Why conveyancers are now reporting entities
Conveyancers sit at the centre of property transactions — the asset class most commonly used by criminals to launder money in Australia. You facilitate the transfer of ownership, manage settlement funds, and interact with both buyers and sellers at the point when significant sums of money change hands. This makes the conveyancing industry a critical point of intervention in the money laundering chain.
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 brings conveyancers within the AML/CTF regime as reporting entities for the first time. This mirrors the approach taken in the UK, EU, and New Zealand, where property professionals have operated under AML/CTF frameworks for years.
Property-based money laundering in Australia typically involves purchasing high-value residential or commercial property with proceeds of crime. The property is then held, renovated, or sold to produce apparently legitimate funds. Without identity verification and transaction monitoring at the conveyancing stage, this scheme is difficult to detect.
By requiring conveyancers to verify client identities, monitor settlement funds, and report suspicious activity, the Tranche 2 reforms create a significant new safeguard against property-based money laundering in Australia.
Relevant legislation
- AML/CTF Act 2006 — the primary legislation governing reporting entity obligations
- Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 — introduces Tranche 2 obligations for conveyancers
- AML/CTF Rules 2007 — detailed requirements for customer identification and record keeping
Which conveyancing services are designated services?
The AML/CTF obligations for conveyancers are focused on the core activities of your profession: property transfers and the management of settlement funds. If you provide any of the following services, you are a reporting entity.
Acting in the purchase or sale of real property
Providing conveyancing services for a buyer or seller in a residential or commercial property transaction — preparing transfer documents, conducting searches, and coordinating settlement.
Managing client settlement funds
Receiving, holding, or disbursing settlement funds, deposits, or other client money in connection with a property transfer. This includes trust account management for conveyancing purposes.
Acting in property transfers between related parties
Assisting in the transfer of property between family members, related companies, or other connected parties — including deceased estate transfers and relationship property settlements.
Residential and commercial property both in scope
Designated services cover both residential and commercial property transactions. If you provide conveyancing for commercial properties, industrial sites, or rural land, those transactions are also subject to your AML/CTF obligations.
Your six core AML/CTF obligations
Once enrolled with AUSTRAC, these obligations apply to all your designated service transactions. There is no turnover threshold or transaction value threshold — the obligations apply from the first transaction.
Customer Identification (KYC)
Verify the identity of all parties you act for in a property transaction before settlement. Individuals require name, date of birth, and address verification. Corporate clients require entity and beneficial ownership identification.
AML/CTF Program
Maintain a written AML/CTF program covering risk assessment, KYC procedures, suspicious activity indicators specific to property transactions, and staff training requirements.
Suspicious Matter Reporting
Lodge a Suspicious Matter Report (SMR) with AUSTRAC within 3 business days when you suspect a client or transaction may be related to money laundering or financial crime. The tipping-off prohibition applies.
Settlement Fund Monitoring
Apply appropriate scrutiny to the source and flow of settlement funds. Unusual payment sources, cash equivalents, or funds from high-risk jurisdictions require enhanced due diligence before settlement proceeds.
Record Keeping
Retain all KYC records, transaction documents, and AUSTRAC reports for at least 7 years. Records must include identity verification sources, transaction details, and copies of any reports lodged.
Annual Compliance Reporting
Submit an annual AML/CTF compliance report to AUSTRAC each calendar year covering your compliance activities, risk assessments, and any changes to your business.
Red flags in property settlement
Your AML/CTF program must train staff to recognise indicators of suspicious activity in property transactions. These are the red flags most commonly associated with property-based money laundering:
Buyer offers to pay deposit or settlement in cash or cash equivalents
Settlement funds arrive from a third party not party to the transaction
Purchase price is significantly above or below the apparent market value
Buyer is from a high-risk jurisdiction or uses an offshore bank account
Buyer refuses to provide identity documents or provides inconsistent information
Transaction involves rapid resale of a recently purchased property
Buyer requests unusual or last-minute changes to settlement arrangements
Property is held through a complex structure with no apparent commercial purpose
Buyer is identified as a Politically Exposed Person (PEP)
Source of funds cannot be reasonably explained by the client's apparent financial position
Identifying a red flag does not mean you must refuse to proceed — it triggers enhanced due diligence. See our Customer Due Diligence Guide for how to respond appropriately.
How IntelliCompli helps conveyancers comply
IntelliCompli is purpose-built for Australian reporting entities including Tranche 2 conveyancers. Our platform covers every aspect of your compliance obligations so you can focus on settlements, not paperwork.
Verifying buyer and seller identity for every transaction adds time to settlements
Digital KYC with automated document and biometric verification — completed in minutes
No existing AML/CTF program tailored to conveyancing practice
Program Builder with conveyancing-specific templates covering settlement and property transfer risks
Uncertainty about how to handle settlement funds from unexpected sources
Built-in red flag indicators and enhanced due diligence workflows for settlement funds
Complex beneficial ownership for company and trust buyers
Structured entity verification with beneficial ownership mapping for corporate purchasers
Staff don't know how to respond to suspicious activity without tipping off clients
Staff training with conveyancing scenarios and tipping-off compliance guidance
Limited time before the 1 July 2026 deadline
Fast-track setup — enrol and build a compliant program in days with guided workflows
Frequently asked questions
Are conveyancers required to comply with AML/CTF laws?
Yes. The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 brings conveyancers within the AML/CTF regime as reporting entities. Conveyancers who assist in property transfers and manage settlement funds must enrol with AUSTRAC by 31 March 2026 and be fully compliant by 1 July 2026.
What is the difference between conveyancers and lawyers for AML/CTF purposes?
Both conveyancers and lawyers who provide conveyancing services are reporting entities under Tranche 2. For conveyancers, their core designated services are conveyancing and settlement fund management — the same as the conveyancing designated service for lawyers. The key difference is that lawyers may have additional designated services (such as creating legal entities or acting in broader financial transactions), while licensed conveyancers are typically regulated only for their conveyancing and settlement activities.
Which conveyancing services are designated services under Tranche 2?
Designated services for conveyancers include: acting in the purchase or sale or transfer of real property on behalf of a client; managing settlement funds and client money in connection with a property transfer; and in some circumstances, acting in the refinancing or transfer of property-related financial arrangements where you hold or manage client funds.
Must I verify identity for both the buyer and the seller?
Yes. You must identify and verify all parties for whom you are acting in a property transaction. If you act for the buyer, you verify the buyer. If you act for the seller, you verify the seller. If you act for both (in states where this is permitted), you verify both. Verification must be completed before you provide the designated service — you cannot proceed with a settlement without completing identity checks.
What is the AUSTRAC enrolment deadline for conveyancers?
Conveyancers providing designated services must enrol with AUSTRAC by 31 March 2026. This applies to all conveyancing businesses, including sole trader conveyancers. Full compliance — AML/CTF program, KYC procedures, transaction monitoring, and AUSTRAC reporting — is required by 1 July 2026.
How do I handle settlement funds under AML/CTF obligations?
Settlement funds are a key focus of AML/CTF compliance for conveyancers. You must verify the identity of the client and, where practical, understand the source of settlement funds. Red flags include cash payments, funds from unexpected third parties, or funds from high-risk jurisdictions. If the source of funds is unusual or cannot be reasonably explained, you may need to apply enhanced due diligence and potentially lodge an SMR with AUSTRAC.
What happens if I notice red flags during settlement?
If you identify red flags during a transaction, you must conduct enhanced due diligence to understand the context. If, after enhanced due diligence, you still have a suspicion that the transaction is connected to money laundering or other serious crime, you must lodge a Suspicious Matter Report (SMR) with AUSTRAC within 3 business days. You must not tell the client you have done so (tipping-off prohibition). In some cases, you may also need to consider whether to proceed with the settlement.
Do small conveyancing businesses need to comply?
Yes. There is no small business exemption under the AML/CTF Act. All conveyancers who provide designated services must comply, regardless of whether they are a sole trader or a large firm. The complexity of your AML/CTF program can be proportionate to the scale and risk profile of your business, but the obligations apply equally to all.
Related guides
Tranche 2 Reform Overview
Everything you need to know about Australia's 2024 AML/CTF amendments and what they mean for conveyancers.
Complete AML/CTF Compliance Guide
The six core obligations every reporting entity must meet under the AML/CTF Act 2006.
Customer Due Diligence
Standard, simplified, and enhanced due diligence for property transaction clients.
KYC Verification
Identity verification requirements for buyers, sellers, and corporate entities under the AML/CTF Rules.
Ready to get your conveyancing practice compliant?
IntelliCompli makes Tranche 2 AML/CTF compliance straightforward for conveyancers. Verify clients digitally, monitor settlement funds, and meet your AUSTRAC obligations before 1 July 2026.