--- title: "Conveyancing Sector AML/CTF Compliance | HeadStart Docs" description: "AML/CTF compliance for Australian conveyancers under Tranche 2. Settlement processes, trust accounts, client due diligence. Download free report." lang: en-AU json-ld: | [ { "@context": "https://schema.org", "@type": "Organization", "name": "HeadStart Docs", "legalName": "HeadStart Docs Pty Ltd", "url": "https://www.headstartdocs.com.au", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png?v=4", "width": 512, "height": 512 }, "description": "AML/CTF compliance digital products and programs for Australian businesses under Tranche 2 regulations. Free program documents and AML Portal. 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QLD and ACT conveyancing is performed by lawyers and covered in the Legal Professionals pack." } }, { "@type": "Question", "name": "What source of funds enquiries do conveyancers need to make?", "acceptedAnswer": { "@type": "Answer", "text": "Conveyancers must make appropriate enquiries about how purchasers are funding their property purchase, including deposits and settlement funds." } }, { "@type": "Question", "name": "Do conveyancers need to verify beneficial ownership?", "acceptedAnswer": { "@type": "Answer", "text": "Yes, when clients are companies, trusts or other structures, conveyancers must identify and verify the beneficial owners behind those entities." } }, { "@type": "Question", "name": "What trust account controls are required for conveyancers?", "acceptedAnswer": { "@type": "Answer", "text": "Conveyancers need AML/CTF controls for trust accounts including transaction monitoring, third-party payment protocols and suspicious activity detection." } } ] }, { "@context": "https://schema.org", "@type": "HowTo", "name": "How to Prepare for AML/CTF Tranche 2 as a Conveyancer", "description": "Step-by-step guide for licensed conveyancers to prepare for AML/CTF Tranche 2 compliance before July 2026.", "totalTime": "P180D", "step": [ { "@type": "HowToStep", "position": 1, "name": "Confirm your services are covered", "text": "Verify that your conveyancing services in NSW, VIC, SA, WA, TAS or NT are captured under Tranche 2 as designated services." }, { "@type": "HowToStep", "position": 2, "name": "Appoint an AML/CTF Compliance Officer", "text": "Designate a senior person in your practice to oversee AML/CTF compliance and act as the primary contact with AUSTRAC." }, { "@type": "HowToStep", "position": 3, "name": "Conduct a risk assessment", "text": "Assess your practice's exposure to money laundering, terrorism financing and proliferation financing risks based on your client base and transaction types." }, { "@type": "HowToStep", "position": 4, "name": "Develop your AML/CTF program", "text": "Create policies and procedures documents tailored to your conveyancing practice operations." }, { "@type": "HowToStep", "position": 5, "name": "Establish customer due diligence procedures", "text": "Implement client identification, verification, beneficial ownership identification and source of funds enquiry procedures." }, { "@type": "HowToStep", "position": 6, "name": "Set up trust account AML controls", "text": "Implement transaction monitoring, third-party payment protocols and suspicious activity detection for your trust accounts." }, { "@type": "HowToStep", "position": 7, "name": "Implement electronic verification", "text": "Set up approved electronic identity verification services for efficient client onboarding." }, { "@type": "HowToStep", "position": 8, "name": "Train staff on AML/CTF obligations", "text": "Provide training to all staff on identifying suspicious matters, reporting obligations and compliance procedures." }, { "@type": "HowToStep", "position": 9, "name": "Enrol with AUSTRAC before July 2026", "text": "Register your practice with AUSTRAC as a reporting entity before the Tranche 2 commencement date." }, { "@type": "HowToStep", "position": 10, "name": "Schedule regular program reviews", "text": "Plan for annual reviews of your AML/CTF program and risk assessment to ensure ongoing compliance." } ], "author": { "@type": "Organization", "name": "HeadStart Docs" } }, { "@context": "https://schema.org", "@type": "WebPage", "name": "Conveyancing Sector AML/CTF Compliance", "url": "https://www.headstartdocs.com.au/conveyancing", "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".sector-hero-description", ".faq-section", ".compliance-obligations" ] } } ] --- We use cookies to enhance your experience and analyse traffic. [Privacy Policy](/privacy) Essential OnlyAccept All [Skip to main content](#main-content) [ ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) ](/) [Home ](/) Features [Programs ](/programs) Resources Sectors [Log in ](/auth) [Portal](/aml-landing) Conveyancing Sector # Licensed conveyancers are designated reporting entities under Tranche 2. Here's what you need to know before 1 July 2026. From 1 July 2026, new AML/CTF compliance obligations (called Tranche 2) will apply to the Conveyancing Sector. AUSTRAC enrolment opens 31 March 2026. ![Licensed conveyancers are designated reporting entities under Tranche 2. Here's what you need to know before 1 July 2026. professionals](/assets/conveyancing-office-CyBI1OMY.jpg) ### For NSW, VIC, SA, WA, TAS and NT conveyancers This pack is for licensed conveyancers in states where non-lawyers can perform conveyancing. **QLD & ACT** - see [Legal Professionals pack](/law-practice). ## The path to 1 July 2026 is defined by clear legislative and regulatory milestones AML/CTF Amendment Act Passed Nov 2024 Finalisation of AML/CTF Rules Aug 2025 Core Guidance from AUSTRAC Oct 2025 Sector-Specific Guidance for Real Estate Early 2026 AUSTRAC Enrolment Opens 31 Mar 2026 Mandatory Compliance Commences 1 Jul 2026 The Australian real estate sector has been assessed as having a high money laundering risk. Professionals are viewed as critical gatekeepers. ## These reforms are driven by ### FATF Standards The primary driver is the Financial Action Task Force (FATF), the global standard-setter for combating financial crime. Australia is a founding member and subject to its peer reviews. ### 2015 Evaluation Gap Australia's 2015 FATF evaluation highlighted a key deficiency: the lack of regulation for "gatekeeper" professions like lawyers, accountants and real estate agents. ### Criminal Exploitation Criminals exploit these professional services to conceal illicit funds, hide beneficial ownership through complex structures and add a veneer of legality to the proceeds of crime. ### Tranche 2 Reforms The Tranche 2 reforms close this long-standing vulnerability, strengthening the integrity of Australia's financial system. ## ML/TF/PF Risks in the Conveyancing Sector The conveyancing sector faces unique money laundering (ML), terrorism financing (TF) and proliferation financing (PF) risks. If an entity offers designated services, they will need to be aware of and assess the risks in relation to their business and services offered. #### Identity Verification Customer due diligence Inadequate verification of customer identity leading to onboarding of high-risk clients. #### Unusual Transactions Transaction monitoring Failure to detect structured payments or unusual transaction patterns. #### Sanctions Exposure Prohibited dealings Risk of inadvertently dealing with sanctioned entities or persons. #### Beneficial Ownership Ownership opacity Complex ownership structures obscuring the true beneficial owners of assets or entities. ### Industry References [NRA: Money Laundering (2024) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/money-laundering-australia-national-risk-assessment-2024)• [NRA: Terrorism Financing (2024) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/terrorism-financing-australia-national-risk-assessment-2024)• [NRA: Proliferation Financing (2022) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/proliferation-financing-australia-national-risk-assessment-2022)• [FATF NRA Guidance (2025) ](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Money-Laundering-National-Risk-Assessment-Guidance.html) ## Who May Be Captured? The key trigger is designated services. If you are unsure whether you are covered, please take advice. Even if you are not covered, you may consider implementing guardrails. Licensed conveyancers All states and territories except QLD/ACT Conveyancing firms Multi-practitioner operations Settlement agents (WA) Western Australian settlement services Property transfer specialists Residential and commercial transfers Whether you are captured depends on the designated services you provide. If unsure whether you're covered, please seek legal advice. Even if you are not covered, you may consider implementing guardrails to ensure you don't accidentally cross lines. ## Once you are a reporting entity, you have six fundamental compliance obligations ### 1. Enrol with AUSTRAC Formally register your practice as a reporting entity. ### 2. Develop & Maintain an AML/CTF Program Create a written, risk-based program tailored to your firm's specific ML/TF risks. This is the cornerstone of your compliance. ### 3. Conduct Customer Due Diligence (CDD) Identify and verify your clients and their beneficial owners before providing a designated service, and monitor them on an ongoing basis. ### 4. Report to AUSTRAC Submit Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs) as required. ### 5. Keep Records Maintain all relevant records of CDD, transactions and your AML/CTF program for prescribed periods. ### 6. Appoint an AML/CTF Compliance Officer Designate a senior individual responsible for the oversight of your program. ## Key AML/CTF Areas for Conveyancers Under Tranche 2, conveyancers face new obligations when providing designated services. Our documentation helps you navigate these requirements with confidence, covering all critical compliance areas. ### Settlement Compliance Procedures for AML/CTF compliance during property settlements and fund transfers. ### Trust Account Management AML/CTF controls for trust accounts, including monitoring, transaction verification and suspicious activity detection. ### Client Identity Verification Initial and ongoing customer due diligence (CDD), including electronic verification methods and document requirements. ### Source of Funds Enquiries Procedures for verifying the source and legitimacy of client funds for property transactions. ### Beneficial Ownership Records Requirements for identifying and verifying beneficial owners of entities involved in transactions. ### Suspicious Matter Reporting Workflows for identifying, escalating and reporting suspicious matters to AUSTRAC. ### Compliance Officer Duties Appointment requirements, role description and ongoing responsibilities for AML/CTF compliance. ## Building an AML Program Building an AML/CTF program for a conveyancing practice requires multiple steps. - AML/CTF program framework for conveyancing practices - Risk assessment worksheet (ML/TF/PF risks) - Client identification and verification procedures - Trust account AML controls and monitoring - Source of funds enquiry procedures - Suspicious matter reporting procedures - Staff Training Register for tracking completion - Compliance officer role description ![Professionals reviewing AML compliance documentation](/assets/legal-consultation-SdDZg_6z.jpg) ## Ready to Get Started? We can help you get a headstart on your AML/CTF program. Program packs from $249, licensed to you permanently. Portal is free with managed CDD, or run your own CDD on BYO-API plans from $20/month. ### A HeadStart on Compliance Sector-specific compliance documents to help you build your AML/CTF program. ### Ready-to-Customise Resources Lawyer-ready to review for your business. ### Training & Record-Keeping Staff Training Register, Compliance Officer appointment documents and portal-based training record-keeping. [Get Started - Conveyancing Sector Edition](/programs/conveyancing-aml-program) From $249 inc GST · or bring your own program HeadStart Docs™ products are developed with reference to publicly available regulatory guidance. This is general information only and does not constitute legal or professional advice. You should seek advice specific to your circumstances before making compliance decisions. ## Free Resources [ ### Conveyancing Sector Industry Report Free Tranche 2 Conveyancing Sector Report. What the industry needs to know. ](/reports/conveyancers)[ ### AUSTRAC Starter Kits When will they be out and what to expect. ](/tranche-2-resources/austrac-starter-kit-conveyancers)[ ### Tranche 2 Guide Guide to the AML/CTF Amendments and Tranche 2. ](/tranche-2) ## Executive Briefing Hear why AUSTRAC targets conveyancing for property-based money laundering ### AML for Conveyancers Duration: 17:15 Share: [](https://www.linkedin.com/sharing/share-offsite/?url=https%3A%2F%2Fopen.spotify.com%2Fepisode%2F3E1z5xIqqzBxbWJf0zx64Y)[](https://twitter.com/intent/tweet?text=AML%20for%20Conveyancers&url=https%3A%2F%2Fopen.spotify.com%2Fepisode%2F3E1z5xIqqzBxbWJf0zx64Y)[]() ### Episode Notes [From $249 ](/programs/conveyancing-aml-program) ### AML/CTF Compliance by Specialisation [Settlement Agents](/conveyancing/settlement-agents)[Licensed Conveyancers](/conveyancing/licensed-conveyancers) Related Sectors: [Real Estate](/real-estate)[Law Practice](/law-practice)[Property Developers](/property-developers) ### Learn More About Conveyancing Compliance [ Getting Started AUSTRAC Starter Kit for Conveyancers ](/tranche-2-resources/austrac-starter-kit-conveyancers)[ Conveyancing Trust Account Red Flags ](/tranche-2-resources/trust-account-red-flags)[ Due Diligence How to Spot a 'Clean Skin' Launderer ](/tranche-2-resources/clean-skin-launderers)[ Red Flags What is 'Structuring'? ](/tranche-2-resources/structuring-property-professionals) ### Free Tools for Conveyancers [Implementation Timeline Key dates and milestones for Tranche 2 compliance ](/timeline)[Readiness Test Assess your compliance readiness in 2 minutes ](/risk-calculator)[Sanctions Screening Search Australian sanctions lists and country risk ](/sanctions-search) ### Related Resources [Conveyancers Report](/reports/conveyancers) ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) [![HeadStart Counsel](/assets/headstart-counsel-logo-dark-DW8mV5rY.png)](https://www.headstartcounsel.com.au/)[![HeadStart Search](/assets/headstart-search-logo-dark-C68UhGXl.png)](/sanctions-search)![HeadStart Verify](/assets/headstart-verify-dark-Dtad3197.png) ### Sectors [Accounting](/accounting)[Business Brokers](/business-brokers)[Buyers Agent](/programs/buyers-agent-aml-program)[Conveyancing](/conveyancing)[Insolvency](/insolvency-practitioners)[Legal](/law-practice)[Nominee Director](/programs/nominee-director-aml-program)[Precious Metals, Stones & Products](/precious-metals)[Property Development](/property-developers)[Real Estate](/real-estate)[TCSPs](/tcsp)[Virtual Address](/virtual-address) ### Resources [Free Resources](/tranche-2-resources)[Decision Trees](/decision-trees)[Tranche 2 Guide](/tranche-2)[Podcast](/podcast)[Free Sector Reports](/sector-reports)[Implementation Timeline](/timeline)[Sanctions Search](/sanctions-search)[AUSTRAC Starter Kits](/tranche-2-resources/austrac-starter-program-kits)[Budgeting for Compliance](/tranche-2-resources/budgeting-amlctf-compliance) ### Programs [Portal + AML Programs](/programs)[Pricing](/pricing)[White Label](/white-label)[External CRMs](/integrations)[AML Portal](/aml-landing)[Plug & Play Technology](/plug-and-play)[Lawyer in the Loop](/features/lawyer-in-the-loop) ### Legal [Terms & Conditions](/terms)[Privacy](/privacy) ### Connect [Programs](/programs)[Podcast](/podcast)[Feedback](/report-problem)[Our Mission](/our-mission)[Partnerships](/partnerships) ### Events [AML Conference 2026](/conference) Powered by Stripe SSL Secured 2026 Ready © HeadStart Docs Pty Ltd (ABN 12 691 347 823). HeadStart Docs™ is a digital publisher and platform provider. We sell digital compliance products including publications and portal access to our AML Portal; we do not provide legal advice or services. The content on this website and in our products is for general information purposes only, does not consider your individual and business circumstances, and should not be relied on as legal advice. Referrals for legal advice can be made, on request, to HeadStart Counsel, the registered trading name of Astris Law Pty Ltd, a related incorporated legal practice with the same director and beneficial owner as HeadStart Docs. You are free to engage any legal practitioner of your choice.