Free AML/CTF program templates for Australian conveyancers

What is an AML/CTF Program?

Your AML/CTF Program is the documented set of policies, procedures and controls your practice uses to identify, assess and manage its money laundering and terrorism financing risks. It must be in place — documented and approved — before 1 July 2026.

The program is not a one-off document. It must be reviewed and updated at least every 3 years, and whenever there is a material change to your risk environment (such as a new type of matter, a new jurisdiction, or a significant change in your client base).

What must the program contain?

AUSTRAC requires your program to address two main areas, sometimes called Part A and Part B:

Part A — AML/CTF Policy (the "what and why")

• Your practice details and the designated services you provide
• Your AMLCO appointment and responsibilities
• A risk appetite statement — your tolerance for ML/TF risk
• How you assess and manage ML/TF/PF risks
• Your obligations under the AML/CTF Act including tipping-off prohibition
• Your approach to independent evaluation
• Senior manager approval and version control

Part B — CDD and Operational Procedures (the "how")

• Step-by-step CDD procedures for each matter type (purchase, sale, transfer, auction)
• Individual, company, trust and SMSF identification checklists
• PEP and sanctions screening procedure
• Enhanced CDD (EDD) process for high-risk clients
• Trust account controls and source-of-funds checks (if applicable)
• Red flag indicators for conveyancing matters
• SMR decision process — when and how to file
• 7-year record retention requirements
• Staff training requirements

The AUSTRAC Conveyancing Starter Kit

AUSTRAC has published a free Conveyancing Program Starter Kit specifically for conveyancers. It includes template documents for both Part A and Part B that are pre-populated with conveyancing-specific content. You can download it from austrac.gov.au.

The starter kit is a strong starting point but is deliberately generic. You will need to customise it to reflect your practice's specific circumstances — your state, your client types, whether you hold a trust account, and your actual risk exposure.

SimpleAML's free templates

SimpleAML provides three ready-to-customise Word templates specifically designed for small Australian conveyancing practices:

• Part A — AML/CTF Policy Statement: Pre-drafted with conveyancing-specific content. Fill in your practice name, AMLCO and state of operation. Takes about 20 minutes to customise.
• Part B — CDD Procedures: Step-by-step procedures for all matter types including the auction 28-day rule. Includes company, trust and SMSF checklists. About 30 minutes to customise.
• Risk Assessment Worksheet: Structured across five risk categories including the trust account risk category specific to conveyancers. Complete this first — before finalising Parts A and B.

Download all three from the SimpleAML templates page.

Getting your program approved

Once your program documents are customised, they must be approved by a senior manager before 1 July 2026. For sole practitioners, approval by the principal conveyancer is sufficient. For larger practices, the principal or a senior manager should sign off.

Once approved, record the approval in the SimpleAML app under the AML/CTF Program tab — including the approver's name, title and the date of approval. This is your compliance evidence.