AML for Conveyancers in Australia
The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) applies to conveyancers who provide certain designated services in Australia. Since Tranche 2 obligations commenced on 1 July 2026, newly regulated conveyancing practices must meet applicable requirements, including customer due diligence, risk management and suspicious matter reporting.
One AML helps conveyancing practices understand their obligations and establish appropriate compliance arrangements, including AML/CTF programs, risk assessments, AUSTRAC enrolment support and staff training.
We’re proud to assist small to enterprise-scale businesses across all industry sectors.
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Are Conveyancers Covered by the AML/CTF Act?
Not all conveyancers are automatically reporting entities. Your obligations depend on whether the services you provide fall within the designated services covered by the AML/CTF Act.
The Tranche 2 reforms extended AML/CTF regulation to certain professional services, including specified services involving property transactions and financial arrangements.
If your practice provides a covered designated service, you may need to meet the applicable reporting entity obligations. The requirements depend on your services, operating arrangements and any relevant exemptions or transitional provisions.
One AML can help assess your services and identify the requirements that apply to your practice.
Which Services Trigger AML/CTF Obligations for Conveyancers?
Relevant designated services may include:
- Assisting with the planning or execution of a transaction to buy, sell or transfer real estate.
- Assisting with the planning or execution of a transaction to sell, buy or transfer a body corporate or legal arrangement.
- Receiving, holding, controlling or managing property to help plan or execute a transaction.
- Assisting with certain equity or debt financing transactions involving a body corporate or legal arrangement.
Not every activity performed by a conveyancer constitutes a designated service. Your practice should assess its actual services against the AML/CTF Act and applicable AUSTRAC guidance.
What AML/CTF Obligations Apply to Conveyancers?
Conveyancing practices covered by the AML/CTF Act must meet the obligations applicable to their designated services. These may include the following requirements.
AUSTRAC Enrolment
Newly regulated conveyancing practices were required to enrol with AUSTRAC in connection with the commencement of Tranche 2 obligations. Enrolment opened on 31 March 2026, with an initial deadline of 29 July 2026 for the newly regulated cohort.
Businesses that begin providing a designated service after commencement must enrol with AUSTRAC within 28 days of first providing that service. If your practice has not yet enrolled, confirm your obligations and address any outstanding requirements promptly.
Risk Assessment and AML/CTF Program
Your practice must identify and assess its money laundering and terrorism financing (ML/TF) risks, considering factors such as the services provided, customer types, transactions, delivery methods and geographic exposure.
The assessment informs your AML/CTF program, which sets out the policies, procedures and controls used to manage those risks and meet your regulatory obligations. Your program should reflect your actual operations and be updated as required.
Customer Due Diligence (CDD)
Customer due diligence involves identifying and verifying customers and assessing the risks associated with your services. Depending on the circumstances, CDD may include:
Verifying customer identities and relevant beneficial owners.
Identifying individuals acting on behalf of customers.
Assessing the nature and purpose of a business relationship or transaction.
Conducting politically exposed person checks and targeted financial sanctions screening where required.
Applying enhanced due diligence to higher-risk situations.
Conducting ongoing due diligence and monitoring for changes in customer risk or unusual activity.
CDD must be completed within the applicable timeframe, subject to relevant exceptions and transitional arrangements. Your procedures should explain how staff conduct checks, document results and escalate concerns.
Suspicious Matter Reporting and Record Keeping
Reporting entities must submit a Suspicious Matter Report (SMR) to AUSTRAC where there are reasonable grounds to suspect that a matter may be relevant to certain offences, investigations or proceedings. A confirmed offence is not necessary.
SMRs are generally due within three business days after the day the suspicion is formed, or within 24 hours where the suspicion relates to terrorism financing.
Your AML/CTF program should explain how staff identify and escalate suspicious activity, assess reporting requirements and submit reports within the required timeframe. Tipping-off restrictions must also be observed.
You must retain the records required under the AML/CTF Act and Rules, including relevant CDD documentation, transaction records, reporting records and program documentation. Retention periods vary according to the record type and applicable requirements.
Transitional Arrangements for Tranche 2 Conveyancers
Although Tranche 2 obligations commenced on 1 July 2026, transitional provisions provide additional time for certain requirements in specified circumstances.For eligible newly regulated entities, the deadline for the first independent evaluation depends on the last two digits of the reporting entity's AUSTRAC account number:
30 June 2029: Both digits are odd.
31 December 2029: The second-last digit is odd and the last digit is even.
30 June 2030: Both digits are even.
31 December 2030: The second-last digit is even and the last digit is odd.
These deadlines apply to the relevant newly regulated cohort. Other transitional provisions may affect CDD processes and compliance officer notification requirements.
Refer to AUSTRAC's official transitional rules guidance to confirm the requirements and deadlines applicable to your practice. One AML can also help you identify relevant transitional arrangements and plan your compliance activities.
How One AML Supports Conveyancing Practices
One AML helps conveyancing practices establish AML/CTF arrangements suited to their services, customers and operational risks.
AML/CTF Program and Risk Assessment
We develop AML/CTF programs tailored to your practice, supported by risk assessments that identify relevant ML/TF risks and inform appropriate policies, procedures and controls.
CDD Procedures, Registers and Record Keeping
We help establish customer due diligence procedures and the documentation needed to support your compliance processes. Depending on your requirements, this may include beneficial ownership checks, sanctions screening, enhanced due diligence procedures and registers for suspicious matter assessments, staff training and employee vetting.
AUSTRAC Enrolment and Staff Training
We assist with AUSTRAC enrolment and help prepare the information required for your application. We also provide training tailored to your team's responsibilities, helping staff understand applicable procedures and how to recognise and escalate concerns.
Independent Evaluation and AMLCO Support
One AML provides independent evaluation services for eligible practices, subject to the required independence arrangements. If we have helped develop or implement your program, the suitability of a subsequent evaluation must be assessed against the applicable independence requirements.
Our AML/CTF Compliance Officer (AMLCO) Support Services provide ongoing assistance with compliance questions, program updates and regulatory developments.
Why Choose One AML?
One AML has worked with over 1,000 reporting entities across Australia and New Zealand, including businesses in real estate, law and conveyancing. We help practices establish AML/CTF arrangements that address their regulatory obligations and support day-to-day operations.
Our services cover program development, risk assessments, implementation support, staff training and ongoing compliance assistance. One AML also has more than 70 verified Google reviews.
We’re qualified to consult for all Phase 1 and 2 reporting entities across Australia.
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Get Your Conveyancing Practice AML-Ready
Whether you need help understanding your Tranche 2 obligations or establishing an AML/CTF compliance program, One AML can help your conveyancing practice meet its regulatory requirements with confidence.
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