LEGAL & CONVEYANCING · TRANCHE 2
AML/CTF compliance for conveyancers and property lawyers
Transactional property and business work is captured. Litigation generally is not. The distinction matters, and so does knowing how privilege and your AML obligations sit alongside each other.
- 1 July 2026AML/CTF obligations begin
- 29 July 2026Enrolment deadline with AUSTRAC
- 2029–2030First independent evaluation, staggered by enrolment identifier
Are you captured?
The regime captures specific professional services, not the profession as a whole. A practice doing conveyancing, business sales and structuring will have captured and uncaptured work running side by side, and the program has to reflect that.
Likely captured
- Conveyancing — acting on the purchase, sale or transfer of real estate
- Acting on the sale or purchase of a business or shares
- Managing client money, accounts or securities
- Forming or managing companies, trusts or other legal arrangements
- Acting as, or arranging for someone to act as, a nominee director, shareholder or trustee
- Providing a registered office or business address
Generally outside scope
- Litigation and dispute resolution
- Family law, criminal law and general advisory work
- Wills and estate planning that does not involve the captured services
Capture depends on the designated services you provide — not on your profession, your licence or your job title.
What you need in place
Enrol and register with AUSTRAC
Every reporting entity has to be on the register. Enrolment is the entry point for everything else, including how your evaluation timing is set.
Appoint an AML/CTF compliance officer
A named person with the authority, seniority and time to run the program — and AUSTRAC has to be notified of the appointment.
Write an ML/TF risk assessment
Covering your customers, the designated services you provide, your delivery channels and the jurisdictions you deal with, with the reasoning visible.
Document your AML/CTF policies
Policies, procedures, systems and controls that follow from the risk assessment, approved by a senior manager rather than filed unread.
Run initial customer due diligence
Identify and verify your customer before you provide the designated service, at a depth that matches the risk you have assessed.
Screen for sanctions, PEPs and adverse media
Screening at onboarding and again over the life of the relationship, with the result recorded either way.
Trace beneficial ownership
Where the customer is a company, trust or other arrangement, identify who ultimately owns or controls it — and show how you got there.
Keep ongoing customer due diligence running
Monitoring is not an onboarding task. Relationships have to be reviewed and re-screened as risk and circumstances change.
Report suspicious matters
Submit suspicious matter reports within the required timeframes, plus threshold transaction reports where they apply to you.
Keep records
Generally seven years, with the retention clock starting at different points depending on the record type.
Train your people
Risk-appropriate AML/CTF training for staff, refreshed over time and delivered to new starters as they join.
Have the program independently evaluated
An independent evaluation of the whole program on the cycle your policies set, with findings tracked to closure.
Work out how privilege interacts with reporting
Legal professional privilege does not disappear under the regime, but it is not a blanket exemption either. Resolve the interaction with your reporting obligations before you need to rely on it.
See the evidence, not just the promise.
How True Comply helps
Client verification by secure link
A conveyancing file isn't held up waiting for someone to visit the office or post certified copies.
UBO tracing inside the matter
Beneficial ownership tracing for corporate and trust clients, done inside the matter rather than beside it.
Captured and uncaptured work, separated
A clear split at intake, so you are not applying full CDD to a litigation file.
Ongoing monitoring across the book
Your client book stays monitored for $1 per person per month.
A program pack for a legal practice
A risk assessment and policy set written for a legal or conveyancing practice.
A named advisor
Someone senior to take the privilege and reporting judgement calls with.
Free to start. $1 per person per month for ongoing monitoring.
Start with your first checks at no cost, then keep your whole client book monitored for a dollar a person a month.
Questions, answered.
Related insights
- Legal & conveyancing
AML/CTF for conveyancers and property lawyers: what actually changed
5 min read
- Scope
‘Are we even captured?’ How AML/CTF scope really works
4 min read
- How to
Beneficial ownership: finding who is really behind a company
5 min read
- How to
Writing your first AML/CTF risk assessment
5 min read
Compliance you can prove.
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