Obligations are in effect·Enrolment deadline: 29 July 2026—21 days remaining
AML/CTF Compliance · Conveyancers & Settlement Agents
AUSTRAC AML/CTF Compliance for Conveyancers — Tranche 2 Guide
Every conveyancer preparing a contract or executing a transfer has been providing a designated service since 1 July 2026 under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) as amended by the AML/CTF Amendment Act 2024. There is no minimum transaction size and no firm size exemption — a sole-practitioner conveyancer in regional Queensland has the same obligations as a national firm. Enrolment must be completed by 29 July 2026.
Built on AUSTRAC official guidance · Built to current law · Firm-specific · No legal knowledge required · Ready in one session
What makes conveyancers different
The conveyancer vs lawyer distinction — and why it matters
AUSTRAC has published a separate Conveyancing Starter Kit — distinct from the Legal Profession Starter Kit — because the risk profile and transaction mechanics of conveyancing differ from general legal practice. Using the wrong Starter Kit, or no starter kit at all, is a common compliance error.
Mixed practices — law + conveyancing — need two risk assessments
If your practice provides both general legal services and conveyancing services, you must address each designated service category separately in your AML/CTF Program’s risk assessment. A single risk assessment covering only “legal services” does not satisfy the obligation for conveyancing work. This is the most common mistake mixed-practice firms make.
Obligations start at retainer — not at settlement
A conveyancer starts providing a designated service when they act on instructions in relation to a property transaction — typically from the time of first retainer, often before contracts exchange. CDD must be completed before or at the time of providing the designated service. Collecting identity verification only at settlement is too late and is a contravention of the AML/CTF Act 2006.
Sole practitioner note
A sole-practitioner conveyancer in regional Queensland has the same AUSTRAC obligations as a national firm. There is no size exemption, no minimum client volume, and no rural or remote carve-out. If you act on property transactions, you must be enrolled and must already have a program and CDD procedures in place, since these obligations commenced 1 July 2026.
Your obligations
What must conveyancers do now that obligations are in effect?
Seven steps every conveyancing practice must complete. Klyvon generates all required documents automatically.
Confirm you are a reporting entity
Every conveyancer preparing a contract or executing a transfer is providing a designated service. No minimum transaction size. No sole practitioner exemption.
Enrol with AUSTRAC by 29 July 2026
Register at online.austrac.gov.au. Enrolment opened 31 March 2026. You need your ABN, practice details, and designated services list.
Appoint a compliance officer and notify AUSTRAC by 29 July 2026
For sole practitioners, you are the compliance officer. For larger practices, appoint a principal or senior conveyancer. Document the appointment in writing.
Build your AML/CTF Program using the Conveyancing Starter Kit
The AUSTRAC Conveyancing Starter Kit must be customised to your practice. Mixed practices (law + conveyancing) need two separate risk assessments.
Train all staff now that obligations are in effect
All conveyancers and support staff involved in property transactions must complete AML/CTF awareness training. Annual refreshers required. Keep records.
Apply CDD from retainer — obligations begin before settlement
Since 1 July 2026, you must verify client identity from the time of retainer — not at settlement. File SMRs within 3 business days of suspicion (24 hours for terrorism financing).
Schedule your independent evaluation
At least once every 3 years (more often if your practice's size or complexity warrants it), arrange an independent evaluation covering your risk assessment, policy design, actual compliance, and risk mitigation effectiveness. A written report goes to your governing body or responsible senior manager. Distinct from your annual internal review.
What you get
What does Klyvon build for your conveyancing practice?
Every document is generated for your specific practice — your name, your compliance officer, your services. Not the AUSTRAC Starter Kit unchanged. Every document is built to current law using AUSTRAC's official guidance for your sector as context — then reviewed and owned by you.
AML/CTF Program
Personalised · Built to current lawYour conveyancing-specific compliance program citing the AML/CTF Act 2006. Covers your ML/TF risk assessment, buyer and seller CDD, beneficial ownership checks, settlement-timing requirements, and reliance provisions.
CDD Templates
Personalised · Built to current lawClient identification forms for individual buyers and sellers, corporate purchasers, and trust clients — with enhanced CDD triggers for cash-intensive settlements, offshore purchasers, and complex ownership structures.
Staff Training Quiz + Certificate
Personalised · Built to current lawScenario-based training covering conveyancing-specific AML/CTF red flags, CDD timing requirements, and how to file an SMR. Generates a dated certificate per staff member.
Compliance Officer Letter
Personalised · Built to current lawFormal appointment letter satisfying the written appointment requirement under the AML/CTF Act 2006. Names your compliance officer and sets out their responsibilities.
Suspicious Matter Report Assistant
Personalised · Built to current lawWhen suspicion arises, you have 3 business days to file with AUSTRAC. Klyvon drafts a formal 6-section SMR from the transaction details you enter — industry-aware language, TTR flag if the amount exceeds $10,000, and your firm's AUSTRAC ID pre-populated. You review and submit. (Limited drafts on Free · high monthly allowance on Essential)
Documents built to current law are a starting point — reviewed and owned by you. All decisions remain with your firm.
Pricing
How much does AML/CTF compliance cost for a conveyancing practice?
Compliance consultants charge $8,000–$50,000 to build your program. Klyvon generates your complete compliance documents from $299/month — documents ready in a single session.
Why Klyvon?
$8,000–$50,000 to build your program
Custom program development
From $299/month — built to current law in one session
Month-to-month · cancel anytime
Klyvon Essential — Conveyancers & Settlement Agents
$299/month
- ✓ AML/CTF Program (risk framework and CDD procedures)
- ✓ CDD Templates
- ✓ Staff Training Quiz + Certificate
- ✓ Compliance Officer Letter
- ✓ SMR Template + AUSTRAC Enrolment Guide
Month-to-month · cancel anytime · Documents ready in one session
Common questions
Common questions from conveyancers about AUSTRAC Tranche 2
Are all conveyancers required to comply with AUSTRAC Tranche 2?
Yes. Every licensed conveyancer or settlement agent who acts in property transactions is a reporting entity under the AML/CTF Act 2006 as amended by the AML/CTF Amendment Act 2024. There is no minimum transaction size, no firm size exemption, and no carve-out for sole practitioners. A sole-practitioner conveyancer in regional Queensland has the same obligations as a national firm.
When does a conveyancer start providing a designated service?
A conveyancer starts providing a designated service when they act on instructions in relation to a property transaction — this typically occurs before contracts exchange, often from the time of first retainer. The obligation to conduct CDD arises at or before the time of providing the designated service, not at settlement. Waiting until settlement to verify client identity is a contravention of the Act.
Do conveyancers need a separate AML/CTF program from lawyers?
Yes. AUSTRAC has published a separate Conveyancing Starter Kit distinct from the Legal Profession Starter Kit. This is because the risk profile and transaction mechanics of conveyancing are different from general legal practice. Mixed practices that provide both legal services and conveyancing services need two separate risk assessments within their AML/CTF Program — one for each service category. This is the most common mistake made by mixed-practice firms.
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. However, the Starter Kit must be customised to your specific practice — your services, clients, risk profile, and compliance controls — before it constitutes a compliant program under the AML/CTF Act 2006. An unmodified Starter Kit is not a compliant AML/CTF Program.
What CDD do I need to collect on my conveyancing clients?
Before acting for a buyer or seller, you must: (1) verify the client's identity — full name, date of birth, and residential address for individuals; (2) for companies, verify the entity's identity (ASIC extract) and identify the beneficial owners; (3) for trusts, verify the trust's identity and the identity of the trustees and controlling parties. Enhanced CDD is required for PEPs, clients from high-risk jurisdictions, and transactions with unusual payment structures.
What is a suspicious matter report and when must I file one?
A Suspicious Matter Report (SMR) must be submitted to AUSTRAC if you know, suspect, or have reasonable grounds to suspect that a transaction is related to money laundering, terrorism financing, or proceeds of crime. For conveyancers, suspicious matters include: buyers unable to explain the source of funds; cash-intensive settlements; purchases through shell companies with unclear ownership; and transactions at prices materially above or below market value. SMRs must be submitted within 3 business days of suspicion arising — or 24 hours for terrorism financing.
Can I rely on a real estate agent's CDD checks?
Yes, in certain circumstances. The AML/CTF Act 2006 allows reliance on CDD completed by another Australian reporting entity for the same transaction. A conveyancer may rely on a real estate agent's identity checks if: (1) the reliance arrangement is documented before relying on it; (2) the agent is an Australian reporting entity; and (3) you retain records of the reliance arrangement and the CDD outcome. You cannot rely on overseas entity checks unless specific AML/CTF Rules conditions are met.
What records do conveyancers need to keep and for how long?
All customer identification records, transaction records, CDD outcomes, SMRs, risk assessments, and AML/CTF Program documents must be retained for a minimum of 7 years from the date the record was made or the transaction completed. Records must be stored securely and be retrievable for AUSTRAC examination or court proceedings.
Who can be the AML/CTF compliance officer at a conveyancing firm?
Any individual — including the principal or sole practitioner — can be appointed as AML/CTF Compliance Officer. There is no requirement for a specialist qualification. For a sole-practitioner conveyancer, this will always be the practitioner themselves. For larger firms, the compliance officer should be a principal or senior employee with sufficient authority to implement controls and report to AUSTRAC. The appointment must be made in writing and documented in the AML/CTF Program.
What are the penalties for conveyancers who don't comply with AUSTRAC?
Under the AML/CTF Act 2006 (Cth), civil penalties for body corporates can reach up to $33,000,000 per contravention (based on current penalty unit rate of $330; re-indexes 1 July 2026) and up to $6,600,000 for individuals (based on current penalty unit rate of $330; re-indexes 1 July 2026). Criminal penalties apply for operating without enrolment and for serious or wilful non-compliance. AUSTRAC publishes all enforcement actions publicly. Conveyancers also face potential consequences with their state licensing authority.
Does Tranche 2 apply to interstate conveyancing matters?
Yes. The AML/CTF Act 2006 is federal legislation that applies across all Australian states and territories. A conveyancer based in Victoria acting on a property transaction in Queensland is subject to AUSTRAC obligations regardless of where the property is located. Enrolment is national — you do not need to enrol separately per state.
How long does it take to get compliant as a sole-practitioner conveyancer?
Using Klyvon, a sole-practitioner conveyancer can generate a customised AML/CTF Program (risk framework and CDD procedures), CDD templates, a staff training quiz and certificate, an SMR template, and a compliance officer letter in one session. Review and final sign-off typically takes 1–2 hours. Building the same documents using a consultant typically takes 4–8 weeks and costs $10,000–$30,000.
Can Klyvon help me write a Suspicious Matter Report?
Yes. Klyvon Essential includes a suspicious matter report assistant. Enter the transaction date, transaction details, and the suspicious elements you observed. Klyvon drafts a formal, AUSTRAC-formatted SMR covering all six required sections — reporter obligations under the AML/CTF Act 2006, matter details, grounds for suspicion, suspicious indicators, recommended action, and AUSTRAC submission notes. You review and submit directly via AUSTRAC Online. Essential includes a high monthly draft allowance.
Does Klyvon include sanctions screening?
Targeted financial sanctions screening is now part of your AML/CTF program obligation under the AML/CTF Rules 2025 — not a separate exercise. Klyvon's generated program includes the required policy controls for targeted financial sanctions. You will still need to screen clients against the DFAT Consolidated List as part of your CDD workflow. Klyvon does not run live screening checks, but your program documents exactly when and how to do it.
How often must conveyancers get an independent evaluation of their AML/CTF program?
At least once every 3 years, and more often if appropriate to the size and complexity of your practice. This is a separate, mandatory requirement under the AML/CTF Act — distinct from your annual internal program review. The independent evaluation must assess: your ML/TF risk assessment against the Act and Rules, the design of your AML/CTF policies, your actual compliance with those policies, and whether you're appropriately identifying, assessing, and mitigating ML/TF risk. Findings go in a written report to your governing body or a responsible senior manager — for a sole practitioner, this means engaging an external, independent evaluator, not self-assessing.
Build your conveyancing AML/CTF program
The 29 July 2026 enrolment deadline is 21 days away.