Australian Conveyancers and AUSTRAC: Your Complete AML/CTF Compliance Checklist for 2026

From 1 July 2026, conveyancers join Australia's anti-money laundering and counter-terrorism financing (AML/CTF) regime. If you act in the sale, purchase or transfer of property, you are likely a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 — which means a set of obligations enforced by AUSTRAC, Australia's financial intelligence regulator.

This is the complete conveyancer AML/CTF compliance checklist for 2026 — the full obligation map, in plain English. It's a starting point, not advice on your specific practice.

First: are you actually in scope?

The regime regulates designated services, not job titles. AUSTRAC's own principle is that it's what you do, not what you are, that counts. Conveyancing — assisting a client in the sale, purchase or transfer of real estate — is a designated service under section 6 of the Act (in the professional-services group known as Table 6), provided in the course of carrying on a business with a geographical link to Australia (the test in section 100).

In practice, almost any practising conveyancer who acts on transfers will be captured. Even one-off or no-fee work can count — size and frequency don't decide the question; the nature of the service does.

The checklist

1. Enrol with AUSTRAC

Get onto AUSTRAC's Reporting Entity Roll. Enrolment opened 31 March 2026; the deadline is 29 July 2026, and anyone starting designated services later must enrol within 28 days (section 51B(1)). You must be enrolled before providing a designated service on or after 1 July. Enrolment is free, via AUSTRAC Online.

2. Conduct your ML/TF risk assessment (your business-wide risk assessment)

Before anything else, assess risk. Every reporting entity must conduct a money laundering, terrorism financing and proliferation financing (ML/TF) risk assessment — the document many call the business-wide risk assessment (BWRA) — appropriate to the nature, size and complexity of your practice. It looks at your customers, services, delivery channels and the jurisdictions you deal with, informed by AUSTRAC's National Risk Assessments.

3. Build your AML/CTF policies

Your risk assessment plus your AML/CTF policies make up your AML/CTF program. The policies are the procedures and controls that manage the risks you identified. AUSTRAC expects a program tailored to your practice — not a template adopted without thought.

4. Appoint an AML/CTF compliance officer

Appoint a compliance officer with the seniority and authority to run the program. In a small firm this is often the principal.

5. Carry out customer due diligence (CDD)

Identify and verify your clients, and identify the beneficial owners behind companies and trusts. CDD is risk-based: lighter for low-risk clients, with enhanced due diligence for higher-risk situations such as overseas buyers, opaque structures or unusual funding. For a full breakdown, see our Know Your Buyer CDD guide for conveyancers.

6. Report suspicious matters (SMRs)

If you suspect on reasonable grounds that a matter relates to money laundering, terrorism financing or another serious offence, you must lodge a Suspicious Matter Report with AUSTRAC — within 3 business days (24 hours for terrorism financing) — without "tipping off" the client.

7. Report threshold cash transactions (TTRs)

Conveyancers rarely handle cash, but if you receive physical currency of A$10,000 or more (or the foreign-currency equivalent) for a designated service, you must lodge a Threshold Transaction Report with AUSTRAC, generally within 10 business days.

8. Train your staff

Everyone involved in designated services needs to understand the red flags, your CDD process and the reporting obligations. Training records must be kept.

9. Keep records, report annually, and schedule your independent evaluation

Keep AML/CTF records (generally for seven years), submit annual compliance reporting, and have your program independently evaluated at least every three years. Newly regulated firms generally have until no earlier than 1 July 2029 for their first evaluation.

What AUSTRAC expects

AUSTRAC has signalled a risk-based, educative approach during the early transition — but obligations are not optional. The expectation is that in-scope conveyancers are enrolled, have a documented risk assessment and policies, have appointed a compliance officer, have trained staff, and can report from day one.

How Veriqua helps

Veriqua is designed to turn this checklist into a working system — generating your risk assessment, running and recording CDD, managing SMR and TTR lodgement workflows, tracking training, and timestamping each obligation as you complete it, so your compliance trail is inspection-ready. Veriqua supports your obligations; it doesn't remove your responsibility as a reporting entity.

Walk your practice through the checklist at demo.veriqua.com.au. Next in this series: customer due diligence and beneficial ownership for conveyancers.