What is the AUSTRAC Conveyancing Starter Kit?

The AUSTRAC Conveyancing Starter Kit is a template AML/CTF Program designed for conveyancing businesses. It is available at austrac.gov.au and provides a starting point for building your risk assessment and CDD procedures. The Starter Kit is a starting point that must be adapted to the practice's designated services, ML/TF risks and controls. Using the unmodified Starter Kit does not by itself establish that the practice has developed and maintains an AML/CTF program appropriate to its business.

What CDD do I need to collect on my conveyancing clients?

A reporting conveyancing practice must undertake initial and ongoing CDD in accordance with the Act and Rules, subject to applicable exceptions. Initial CDD includes establishing the customer's identity, the identity and authority of anyone acting for the customer, beneficial ownership for a non-individual customer, applicable politically exposed person and targeted-financial-sanctions status, and the nature and purpose of the relationship or occasional transaction. The information collected and verified must be appropriate to the customer's ML/TF risk. Enhanced CDD applies in the circumstances specified by section 32; a transaction characteristic does not automatically create an ECDD obligation unless the statutory conditions apply.

Can I rely on a real estate agent's CDD checks?

A reporting entity may rely on CDD carried out by a third party only through an arrangement that satisfies the applicable Act and Rules requirements. The reporting entity must assess the third party and document the arrangement and assessment as required. A real estate agent's involvement in the same transaction does not, by itself, establish that the conveyancer may rely on the agent's checks.

What are the penalties for conveyancers who don't comply with AUSTRAC?

For a contravention of an applicable civil penalty provision, the Federal Court may order a civil penalty. The statutory maximum can be 100,000 penalty units for a body corporate and 20,000 penalty units for a person other than a body corporate. At the $364 penalty-unit rate effective from 1 July 2026, those maxima are $36,400,000 and $7,280,000 respectively. These are maximum amounts a court may order, not automatic penalties for every instance of AML/CTF non-compliance. The applicable consequence depends on the provision contravened and the circumstances.

Does Tranche 2 apply to interstate conveyancing matters?

The AML/CTF Act is Commonwealth legislation. Whether a conveyancer is a reporting entity depends on whether they provide an applicable designated service under the Act, not solely on the Australian state or territory in which the practice or property is located. A practice does not enrol separately with AUSTRAC for each state.

Does Klyvon include sanctions screening?

The AML/CTF Rules require AML/CTF policies to address controls that prevent prohibited dealings with assets connected to persons designated for targeted financial sanctions. Klyvon's generated program includes policy controls addressing targeted financial sanctions. Klyvon does not perform live sanctions-screening checks; the reporting entity remains responsible for implementing appropriate controls.

I started providing a designated service after 1 July 2026 — do I still need to enrol by 29 July 2026?

The 29 July 2026 transitional date applied to newly regulated entities already providing an applicable new designated service before 1 July 2026, and that date has passed. Under the standard rule, a person must apply to enrol no later than 28 days after the day they start providing a designated service.

Updated August 2026

Field Guide · Conveyancers & Settlement Agents

AUSTRAC AML/CTF compliance for conveyancers and settlement agents

AML/CTF coverage depends on whether a conveyancing practice provides an applicable designated service. Where the obligations apply, practice size alone does not remove them, and CDD must occur before the applicable designated service is provided, subject to statutory exceptions.

Build your conveyancing AML/CTF program →See CDD timing

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Steps to compliance: 3 days
SMR lodgement

Australian conveyancers and settlement agents may be regulated by AUSTRAC when they provide applicable designated services involving property transactions; coverage depends on the services performed, not simply on professional title or practice size. Where the obligations apply, the practice must enrol with AUSTRAC, designate and notify an AML/CTF compliance officer, maintain an AML/CTF program, undertake customer due diligence, train relevant personnel, retain required records and submit required reports.

⚠ The 29 July 2026 transitional enrolment deadline has passed. Practices providing designated services should check that their current enrolment details and obligations are up to date.austrac.gov.au ↗

In this guide

Who is regulated When CDD must occur Conveyancer vs lawyer — why it matters What an in-scope practice must do Focused FAQs Get compliant with Klyvon

I. Designated-service scope

Which conveyancing practices are regulated?

Coverage depends on the services performed, not professional title or practice size alone.

conveyancer or settlement agent is a reporting entity if they provide an applicable designated service under the AML/CTF Act 2006. A sole practitioner that provides an applicable designated service is not outside the regime merely because the practice is small.

If you are unsure whether your services are covered, use Klyvon’s AML/CTF scope checker.

II. CDD Timing

When must a conveyancing practice complete initial CDD?

Before providing the applicable designated service, subject to the Act's exceptions.

reporting entity must undertake initial CDD before providing the applicable designated service, subject to statutory exceptions. The relevant point in a conveyancing matter depends on when that service begins to be provided under section 6. Practices should identify that point in their workflow rather than treating settlement as the universal trigger.

“AML/CTF coverage is determined by whether the person provides a designated service. A sole practitioner that provides an applicable designated service is not outside the regime merely because the practice is small.”

III. Conveyancing and Legal Services

The conveyancer vs lawyer distinction — and why it matters

AUSTRAC publishes a separate Starter Kit for conveyancing because the risk profile genuinely differs from general legal practice.

Mixed practices must address each applicable designated service

If a practice provides both designated legal and conveyancing services, its ML/TF risk assessment and AML/CTF policies must identify and address each applicable service and the associated risks. AUSTRAC provides separate sector risk-assessment materials, but that does not necessarily require two separately documented AML/CTF programs.

Sole practitioner note

A sole practitioner that provides an applicable designated service is subject to the relevant AML/CTF obligations. Practice size, client volume or location alone does not determine whether the service is designated.

Practices that also provide designated legal services can review the AUSTRAC AML/CTF guide for lawyers. For the other party in a property transaction, see the AML/CTF guide for real estate agents.

IV. Core Operational Requirements

What an in-scope conveyancing practice must do

The existing obligations cover enrolment, governance, an AML/CTF program, training, CDD, reporting, record keeping and independent evaluation where applicable.

Confirm you are a reporting entity

Review the services your practice provides and determine whether any are designated services under section 6. Coverage is service-based, not based on professional title or practice size alone.

Enrol with AUSTRAC now if not enrolled

Register through AUSTRAC Online if your practice provides a designated service and is not enrolled. The 29 July 2026 transitional deadline has passed; the standard enrolment timing applies to practices that start providing a designated service later.

Appoint a compliance officer and notify AUSTRAC

Designate an eligible individual at management level with sufficient authority, independence and access to resources and information. The individual must meet the applicable residency and fit-and-proper requirements. Notify AUSTRAC within 14 days after designation.

Build your AML/CTF Program using the Conveyancing Starter Kit

Adapt the AUSTRAC Conveyancing Starter Kit to your practice's designated services, ML/TF risks and controls. If the practice provides more than one category of designated service, its risk assessment and policies must address each applicable category.

Train all staff now that obligations are in effect

Provide initial and ongoing AML/CTF training to personnel who perform AML/CTF functions. Training must be appropriate to their functions, relevant ML/TF risks and responsibilities under your AML/CTF policies.

Apply CDD before providing a designated service

Before service

Since 1 July 2026, undertake CDD before providing the applicable designated service, subject to the Act's exceptions. Standard SMR deadlines are 3 business days after suspicion is formed or 24 hours for terrorism-financing suspicions. Retain program, CDD and transaction records for their applicable statutory periods.

Schedule your independent evaluation

Where the Part 1A obligations apply, the evaluation frequency must be appropriate to the nature, size and complexity of the business and at least once every 3 years. Transitional rules stagger the first evaluation deadline for newly regulated entities.

V. Focused FAQs

Common questions from conveyancers

For the standard post-commencement timing, see the AUSTRAC 28-day enrolment rule and worked examples.

Primary sources

AUSTRAC — Tranche 2 reform guidance

Updated August 2026 · Klyvon Compliance Team

VI. Klyvon Resources

Five compliance resources for your practice

Materials based on your practice information that require review, approval, adoption and implementation by the practice.

AML/CTF Program

Conveyancing-focused program material addressing the practice's ML/TF risk assessment, applicable designated services, CDD, beneficial ownership and permitted reliance arrangements.

CDD Templates

Client-identification templates for individual and non-individual customers, designed to be adapted to the applicable CDD requirements and the customer's assessed ML/TF risk.

Role-Based Staff Training + Certificate

Initial and ongoing training materials tailored to relevant personnel's functions, ML/TF risks and responsibilities, with completion records for the practice to retain under the applicable program-record rule.

Compliance Officer Letter

A record for documenting the practice's compliance-officer designation. The practice remains responsible for confirming eligibility, completing required due diligence and notifying AUSTRAC.

SMR Assistant

Klyvon prepares an SMR draft from information entered by the user. The reporting entity remains responsible for determining whether a reporting obligation arises, reviewing the draft and submitting an accurate report through AUSTRAC Online.

VII. How Klyvon Helps

Compliance doesn’t end at enrolment — Klyvon runs alongside your practice

Klyvon provides program, risk-assessment and CDD materials for your practice to review and implement. It also supports training records, review-date tracking and SMR drafting, while the reporting entity remains responsible for its decisions and statutory obligations.

Risk assessment, built to your practice

A documented ML/TF risk assessment that identifies and addresses each applicable designated service and the associated risks.

Mandatory training, by role — not a generic quiz

Training materials and completion records support initial and ongoing training appropriate to each relevant person's functions, ML/TF risks and responsibilities.

SMR drafting when suspicion arises

Prepare an SMR draft from the matter details entered for review by the reporting entity before submission through AUSTRAC Online.

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What is an AML/CTF Program?

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How to Submit an SMR to AUSTRAC

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What Compliance Actually Costs

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AUSTRAC Penalty Register

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All resources

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