Know Your Buyer: AML/CTF Customer Due Diligence for Australian Conveyancers 2026

On every settlement, a conveyancer deals with the exact client types the AML/CTF regime watches most closely — individuals, companies and trusts. From 1 July 2026, identifying and verifying those clients isn't just good practice; it's a legal obligation. This is the practical guide to customer due diligence (CDD) and beneficial ownership for conveyancers.

What CDD is

CDD is the process of knowing who your client is, verifying it from reliable sources, assessing the money-laundering risk they present, and keeping that picture current. It's the conveyancing equivalent of the know-your-customer (KYC) checks banks have run for years.

The reforms make CDD risk-based: the depth of your checks scales to the risk of each client, rather than a fixed one-size process. And it's ongoing — not a single gate at the start of a matter.

Who you need to identify

For a property matter, you generally identify and verify the clients to whom you provide the designated service:

• The buyer (where you act for them) and the seller / vendor (where you act for them).
• Beneficial owners — the real individuals who ultimately own or control a client that is a company or trust.
• Anyone acting on the client's behalf — for example under a power of attorney — and their authority to act.

The three purchaser types on your desk

Individuals. Establish and verify full legal name, date of birth and residential address, using reliable, independent sources — government ID or, increasingly, accredited electronic identity verification, which is faster and leaves a cleaner audit trail.

Companies. Collect the company's details and registration, then look through the company to the individuals who ultimately own or control it (typically those holding more than 25%, though control can exist below that through other means). A company name and ACN alone is not enough — you need the humans behind it.

Trusts. This is where conveyancers most often get caught out. For a trust purchaser, identify the trustee(s), understand the beneficiaries or class of beneficiaries, and identify who controls the trust. Where structures are layered — entities owning entities — trace the chain until you reach the natural persons in control.

When enhanced due diligence applies

Step up to enhanced customer due diligence (EDD) where a client or transaction is higher risk. Common triggers in conveyancing include:

• Overseas buyers and offshore funding, particularly from higher-risk jurisdictions.
• Politically exposed persons (PEPs) — senior officials, their family and close associates.
• Complex or opaque ownership with no clear commercial rationale.
• Third-party funders — someone other than the buyer providing the money.
• Source-of-funds concerns — funds that don't fit the client's profile.

EDD can include taking reasonable steps to understand the client's source of funds or wealth, extra verification, and senior sign-off. Equally, simplified due diligence is available for clients you've assessed and documented as genuinely low-risk — so not every buyer needs the heaviest treatment. The principle throughout is proportionality.

Keep it current

Because CDD is ongoing, keep client information up to date and watch for activity that doesn't fit — a sudden change of funder, a new offshore party, a structure that shifts mid-matter. If the picture starts to look suspicious, that may trigger a Suspicious Matter Report. Keep records of what you did — generally for seven years.

How Veriqua helps

Veriqua's KYC module is entity-type-aware — it knows an individual is not a company is not a trust, and walks you through the right identification path for each. It is designed to trigger identity verification, map beneficial-ownership chains through layered structures, flag when enhanced (or simplified) due diligence applies, run PEP and sanctions screening, and keep a timestamped, auditable record for every client on every settlement.

Veriqua supports your CDD; the responsibility to assess and manage client risk remains with your practice.

See CDD built for conveyancing at demo.veriqua.com.au. Next in this series: red flags in property settlements and how to report them.