AML/CTF for conveyancers — what you need to do before 1 July 2026

What is AUSTRAC Tranche 2?

Australia's Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) has applied to banks, casinos and other high-risk sectors since 2006. Tranche 2 is the long-awaited expansion of those obligations to a new group of "designated service" providers — including conveyancers, real estate agents, accountants, lawyers and dealers in precious metals.

The reforms were passed by Parliament in late 2024. For conveyancers, the new obligations take effect on 1 July 2026.

Is my practice in scope?

If your practice does any of the following, you are a reporting entity and the obligations apply to you:

• Assisting a client with the purchase of real estate
• Assisting a client with the sale of real estate
• Assisting a client with the transfer of real estate (including family transfers, gifts and estate transfers)
• Assisting with transactions involving body corporate interests or legal arrangements relating to real estate

It does not matter whether you are a sole practitioner, a small practice or a larger firm. It does not matter whether the property is residential or commercial. If you provide conveyancing services to clients, you are in scope.

Law firms that provide conveyancing services are also in scope — but are covered under the legal practitioner provisions of the Act, not the conveyancer provisions specifically. The obligations are substantively the same.

What obligations apply from 1 July 2026?

Once your obligations commence, you must:

1. Enrol with AUSTRAC — registration as a reporting entity. The deadline is 29 July 2026, but you must be enrolled before providing designated services from 1 July.
2. Have an AML/CTF Program in place — a documented set of policies, procedures and controls. Must be approved and operational from day one.
3. Conduct Customer Due Diligence (CDD) — verify the identity of your clients before or at engagement. Different rules apply for purchases, sales, transfers and auction matters.
4. Screen for PEPs and sanctions — check clients against politically exposed person lists and DFAT's consolidated sanctions list.
5. File Suspicious Matter Reports (SMRs) — if you have reasonable grounds to suspect a transaction involves money laundering or terrorism financing.
6. Keep records for 7 years — all CDD records, transaction records and program documents must be retained.
7. Appoint and notify an AMLCO — notify AUSTRAC of your AML/CTF Compliance Officer by 29 July 2026.
8. Conduct an independent evaluation — at least every 3 years. First evaluation expected no earlier than 1 July 2029 for newly regulated entities.

Key dates at a glance

What do I need to do right now?

With the 1 July 2026 deadline approaching, the priority actions for most conveyancing practices are:

1. Complete your practice risk assessment using the AUSTRAC Conveyancing Starter Kit
2. Build and approve your AML/CTF Program (Parts A and B)
3. Vet all staff and document their checks
4. Complete AML/CTF training for all staff before go-live
5. Enrol with AUSTRAC from 31 March 2026
6. Start recording client CDD from 1 July 2026

SimpleAML guides you through each of these steps in the free app. Download the free templates to build your program documents, then use the app to record approvals, track staff vetting and manage your ongoing matter register.