Conveyancing practices · Table 6, professional services
Last checked 25 September 2026 against the AML/CTF Act compilation C2026C00274, the AML/CTF Rules 2025 (F2025L01026) and the Transitional Rules 2026 (F2026L00393)
If your practice acts on the sale, purchase or transfer of real estate, it has had AML/CTF obligations since 1 July 2026. The conveyancer edition is for practices that do not operate under a legal practising certificate. Lawyers who do conveyancing use the legal practice edition.
s 6 Sch 3 item 11 AUSTRAC professional designated services
Not sure your practice is regulated? Work through our questions, or use AUSTRAC's tool (AUSTRAC website, opens in a new window).
AUSTRAC's conveyancer starter kit is free
AUSTRAC publishes a free program starter kit for conveyancing practices. If your practice fits AUSTRAC's profile and you have time to customise it, it may be all you need. Our conveyancer edition is built on it, openly and with attribution.
AUSTRAC's conveyancer starter kit (AUSTRAC website, opens in a new window)
01 Scope
Table 6 in section 6 of the Act lists the professional services that are designated. These are the items a conveyancing practice is most likely to provide. The summary is ours; the wording of the Act decides.
| Item | The service, in short | Your customer | Conveyancing example |
|---|---|---|---|
| 1 | Assisting a person to plan or carry out a transaction to sell, buy or otherwise transfer real estate, or acting for them in it, other than under a court or tribunal order | Your client | Acting for a buyer or a seller; a family transfer with no price |
| 3 | Receiving, holding and controlling (including disbursing), or managing, a client's money or property as part of a transaction, unless section 6(5C) applies | Your client | Client money held in your trust account, where you control when it is paid out |
| 2 | Assisting in a transaction to sell, buy or transfer a company, trust or other body corporate or legal arrangement | Your client | Acting on the transfer of a unit trust or a company |
s 6 s 6(5C) AUSTRAC professional designated services
When the service starts. In AUSTRAC's guidance, you start providing the service when you act on instructions and a transaction exists. In a private sale, that is when buyer and seller agree the price, in words or in writing. At an auction that meets reserve, it is when the buyer is successful. General advice on the buying process before then is not a designated service. AUSTRAC professional designated services
Not designated: a transfer made under an order of a court or tribunal, such as one following a court-ordered grant of probate or letters of administration. s 6 AUSTRAC professional designated services
You decide, and you write the decision down
Whether a service is designated is your practice's decision, made on the Act and AUSTRAC's guidance. Use AUSTRAC's Check if you may be regulated tool (opens in a new window), keep the result, and record your decision. Documents 01 and 28 of the conveyancer edition are built for that record. Where the answer is unclear, get legal advice.
02 Where practices get caught out
AUSTRAC lists holding a buyer's funds and disbursing trust funds at settlement among the conveyancing steps under item 1. Item 3 separately covers receiving, holding and controlling a client's money as part of a transaction, and AUSTRAC gives trust-account funds you control as an example. Item 3 does not apply in the circumstances in section 6(5C). They include payment of your own fees, money paid under a court or tribunal order, payments to or from government bodies, courts and licensed insurers, and a service that is any other designated service. Record which applies to your trust account, and why. s 6 s 6(5C) AUSTRAC professional designated services
Rules 6-32 allows delayed checks under section 29 for a Table 6 item 1 client who is, or will be, the buyer or transferee. The checks must be finished by the earlier of 28 days after exchange and 3 days before the initially agreed settlement day. Rules 6-32 gives no such delay for a seller client. For a seller, the general rule in Rules 6-12 applies instead, and it is stricter: some checks come first, the rest must be finished within 20 business days of starting, and no money may be transferred for the client until they are complete. s 29 Rules 6-32 Rules 6-12
Rules 6-33 lets you treat part of your checks as done (the client's beneficial owners, their politically exposed person and sanctions status, and anyone they act for) if you take part in an arrangement with the agent, or another reporting entity in the deal, which will collect and verify your client's details within 28 days after exchange. It applies only where conveyancing is the only designated service you provide to that client, so a client whose money you hold as a separate item 3 service does not qualify. You still confirm an individual client is who they say they are, rate the client's risk, collect their details and check anyone acting for them. You must be able to obtain the agent's information and verification data at least 3 days before the initially agreed settlement day, with each party's responsibilities, including record-keeping, written down. s 28 Rules 6-33 Rules 5-20
It is an offence to disclose that a suspicious matter report has been, or must be, made where that would or could reasonably be expected to prejudice an investigation. The crime-prevention exception in section 123(4) is for legal practitioners, qualified accountants, their firms and persons specified in the Rules. A licensed conveyancer is not named in the Act or specified in the Rules, so do not assume the exception covers you. s 123 Rules 5-13
03 The conveyancer edition
The edition holds the 25 program documents every edition has: the risk assessment, the policies, the process document, client due diligence (CDD) forms, registers and the reporting calendar. The kit page lists them all. The conveyancing wording runs through them: the risk assessment starts from AUSTRAC's conveyancing risk assessment, and the policies carry the settlement-verification clause Rules 5-20 requires. Then come four documents of its own:
The window for delayed checks on a buyer client, verifying before settlement, what to do when a client will not provide what you need, and the suspicious matter decision.
The Rules 6-33 arrangement seen from your side: when the agent relies on you, when you rely on the agent, and each party's responsibilities in writing.
Whether your handling of settlement money is item 3, and which section 6(5C) exclusions apply to fees and incidental amounts.
For practices that also act on transfers of a company or trust (item 2): AUSTRAC's separate onboarding and CDD forms for the four client types, and a second risk assessment.
AUSTRAC's original files are not in our zip. You can download them free from AUSTRAC's conveyancer kit document library (opens in a new window) and compare them with ours.
Built for the practices AUSTRAC's kit was built for
AUSTRAC designed its conveyancer kit for practices that only assist with transactions to sell, buy or transfer real estate or a body corporate or legal arrangement (such as a company or trust), have 15 or fewer personnel (counting administrative staff), are not lawyers operating under a practising certificate, mostly deal with individual clients who are Australian residents, do not regularly deal with high-risk clients or overseas property, only handle client funds directly related to real estate transactions, offer no fully remote self-service, do not sell property they own, are not taking over another business or its clients, and are not part of a large reporting group, foreign branch or subsidiary. Outside that profile, AUSTRAC says you "cannot rely on the starter kit to meet AUSTRAC's regulatory expectations". The same goes for our edition, which is built on it. AUSTRAC conveyancer kit: getting started
04 What the law requires
| Obligation | In short | Law |
|---|---|---|
| Enrolment | Enrol on AUSTRAC's Reporting Entities Roll. You apply directly to AUSTRAC; you do not need us for it. | s 51B |
| AML/CTF program | A written ML/TF risk assessment and AML/CTF policies, documented before your first designated service and approved by a senior manager | s 26B s 26C s 26F s 26P Rules 5-15 |
| Compliance officer | A person at management level who is a resident of Australia and fit and proper, designated within 28 days of your first designated service; AUSTRAC told within 14 days. A sole conveyancer can be the governing body, the senior manager and the compliance officer, and then does not report to themselves. | s 26J s 26K s 26M Rules 5-7 AUSTRAC sole traders and micro businesses |
| Client checks | Who the client is, their beneficial owners, politically exposed person and sanctions status, and the purpose of the work, before you act unless the Rules allow a delay; then ongoing checks | s 28 s 29 s 30 |
| Reports | Suspicious matters within 3 business days of forming the suspicion (24 hours for terrorism financing); physical currency of A$10,000 or more within 10 business days | s 41 s 43 |
| Records | Kept for 7 years | s 107 s 111 s 116 |
05 Key dates
Program, client due diligence, reporting and record-keeping obligations began for professional services (Table 6), including conveyancing.
Enrolment was due for practices already providing a Table 6 service on 1 July 2026. A practice that starts later has 28 days from its first designated service. A missed date does not end the obligation: it continues until you enrol.
Not enrolled yet? You enrol directly with AUSTRAC. You do not need to buy anything from us to do it. Enrol with AUSTRAC (opens in a new window)
AUSTRAC said it had begun issuing section 167 notices to businesses that appear to be providing designated services but have not enrolled.
Your first annual compliance-report period ends.
Last day to lodge your first annual compliance report.
First independent evaluation, if you were in the 29 July 2026 enrolment group: before 30 June 2029, 31 December 2029, 30 June 2030 or 31 December 2030, depending on the last two digits of your enrolment identifier.
As at 17 September 2026, AUSTRAC's enrolment table listed 1,600 conveyancer enrolments. AUSTRAC Enrol with us overview
06 Done for you
You pay once, download the full kit straight away, and receive the conveyancers intake questionnaire. We send your draft documents within 5 business days of receiving your complete intake.
Band 1 · 1–3 personnel
A$990 one-off, includes GST of A$90.00
A sole conveyancer or a practice of 1 to 3 personnel, one office.
Independent. Not affiliated with, or endorsed by, AUSTRAC or the Australian Government.
Band 2 · 4–8 personnel
A$1,490 one-off, includes GST of A$135.45
4 to 8 personnel.
Independent. Not affiliated with, or endorsed by, AUSTRAC or the Australian Government.
Band 3 · 9–15 personnel or mixed service lines
A$2,490 one-off, includes GST of A$226.36
9 to 15 personnel, two offices, or heavy trust-account work alongside company or trust transfers.
Independent. Not affiliated with, or endorsed by, AUSTRAC or the Australian Government.
We do not act as your compliance officer, lodge reports for you or carry out your independent evaluation. If your intake shows your practice is outside AUSTRAC's starter-kit profile or has more than 15 personnel, we tell you and refund you in full before any work starts. Full Setup details · All prices
07 Straight answers
Table 6 item 1: assisting a person to plan or carry out a transaction to sell, buy or otherwise transfer real estate, or acting for them in it, other than under a court or tribunal order. Handling a client's money in the transaction also needs a decision under item 3, subject to the exclusions in section 6(5C). If you also help transfer a company or trust, that is item 2, and AUSTRAC's conveyancer kit has a separate set of forms for it. s 6 s 6(5C)
The legal practice edition. AUSTRAC sends legal practitioners who provide conveyancing to its legal profession kit, which covers their ethical obligations and legal professional privilege. The conveyancer edition is for practices that do not operate under a legal practising certificate. AUSTRAC conveyancer kit: getting started
Before the service starts, as a rule. Where your client is the buyer, section 29 and Rules 6-32 let you finish them later, if the delay is essential to avoid interrupting business and the extra risk is low, but no later than the earlier of 28 days after exchange and 3 days before the initially agreed settlement day. Rules 6-32 does not cover a seller client. The general delay rule in Rules 6-12 is stricter: some checks come first, the rest within 20 business days, and no money transferred for the client until they are done. The conveyancer edition finishes a seller's checks before acting, as AUSTRAC's conveyancer policy does. Where conveyancing is the only designated service you provide to a client, on either side, you can also rely on an arrangement with the agent under Rules 6-33 for part of the checks. Your policies must then say how you will verify before settlement if the agent's data does not arrive. s 28 s 29 Rules 6-12 Rules 6-32 Rules 6-33 Rules 5-20
Not as a matter of routine. Two kinds of transaction report can arise. A threshold transaction, involving A$10,000 or more in physical currency (notes and coins), is reported within 10 business days. Electronic settlement funds are not physical currency. A suspicious matter report is due within 3 business days of forming a suspicion (24 hours for terrorism financing), whatever the amount or the way it was paid. s 43 s 41 s 5
A sole conveyancer or a practice of 1 to 3 personnel: Band 1. A practice of 4 to 8 personnel: Band 2. A practice of 9 to 15 personnel, with two offices, or with heavy trust-account work alongside company or trust transfers: Band 3. If you are unsure, email [email protected] with your headcount and services before you pay.
More detail: AML/CTF guides and the sources we rely on.
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