AML/CTF Compliance for Conveyancers — Tranche 2 Guide

Australian conveyancers are now captured by AUSTRAC's Tranche 2 reforms. From 1 July 2026, if you provide conveyancing services in connection with the transfer of real estate, you must comply with the AML/CTF Act.

When does the conveyancing obligation begin?

Unlike lawyers, conveyancers typically cannot delay KYC — the obligation begins when you accept instructions to act. However, AUSTRAC does allow delayed initial CDD in limited circumstances where it would interrupt the ordinary course of business and the additional risk is low.

In practice: complete KYC on your client as early as possible in the transaction — ideally before exchange.

What you must verify for property transactions

For individual clients: full name, date of birth, address, verified against a government-issued ID document.

For company purchasers: company name, ACN, registration status, plus identity of all directors and beneficial owners (25%+).

For trust purchasers: trust name, trustee identity, settlor, appointor, and beneficiaries (or beneficiary class).

Red flags specific to conveyancing

Purchase funded by overseas transfers from high-risk jurisdictions
Third-party payment of deposit or purchase price
Client cannot explain source of funds
Rapid resale — property bought and resold quickly
Client shows no interest in property details
Multiple purchasers with no obvious connection

Building your AML/CTF program

Every conveyancing practice needs a written AML/CTF program approved by senior management. This must include customer risk assessment methodology, KYC procedures, ongoing monitoring requirements, SMR procedures and staff training records.

How CompliDesk supports conveyancers

CompliDesk provides a guided KYC and compliance workflow purpose-built for Tranche 2 entities. Each client gets a compliance checklist — identity verification, risk questionnaire, screening, and risk assessment — with a downloadable evidence pack for your files.

CompliDesk helps all Tranche 2 entities stay compliant.

Whether you're a lawyer, accountant, real estate agent, conveyancer or TCSP — CompliDesk guides you through every step of your AUSTRAC obligations. Sign up free today.

AML/CTF Compliance for Conveyancers: AUSTRAC Tranche 2 Guide 2026