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Rules Mate

Do conveyancers need to enrol with AUSTRAC?

The AML/CTF Tranche 2 test for conveyancers, from the designated-service tables in section 6 of the AML/CTF Act and AUSTRAC's sector guidance.

Short answer: Yes

A conveyancer who assists a client to plan or execute a real estate transaction provides a designated service under table 6, item 1 of section 6 of the AML/CTF Act. That is the core of conveyancing work, so in practice every conveyancing practice acting in property transactions must enrol, and must do so within 28 days of first providing the service.

The designated services that catch conveyancers

AML/CTF Act referenceServiceCustomer for due diligence
s 6 table 6 item 1Assisting a person to plan or execute a real estate transaction (not under a court order)The person assisted
s 6 table 6 items 2–4Assisting with the sale or purchase of a body corporate or legal arrangement; holding, controlling or managing client money or property for a transaction; equity or debt financingThe person assisted

Real estate customer due diligence can be delayed: for real estate the deadline is the earlier of 28 days after exchange or 3 days before settlement (Rules r 6-32(4)).

Carve-outs and exemptions to check

  • Transfers made under a court order are excluded from table 6 items 1 and 2.
  • Leases of 30 years or less, easements, mortgagee interests and standalone licences to occupy are outside the definition of real estate.

Enrolment deadlines and what follows

  • Enrol within 28 days of first providing a designated service (s 51B). For a business already providing the service on 1 July 2026, that was 29 July 2026.
  • Each day a designated service is provided while unenrolled can be a separate contravention (s 51B(2C)).
  • Notify AUSTRAC of changes to enrolment details within 14 days (s 51F, Rules r 3-9), including adding a new designated service.
  • Designate an AML/CTF compliance officer within 28 days of first providing a designated service (s 26K) and notify AUSTRAC within 14 days (s 26M). For newly regulated businesses the transitional deadline was the later of 29 July 2026 or 14 days after enrolling (Transitional Rules s 19).

Enrolment is the first step, not the last

An enrolled business must also have an AML/CTF program before it provides a designated service: an ML/TF risk assessment plus AML/CTF policies covering customer due diligence, reporting (suspicious matters within 3 business days, threshold transactions of $10,000 or more in cash within 10 business days), record keeping, personnel due diligence, training and governance. The first annual compliance report covers 1 July 2026 to 30 June 2027 and is due by 30 September 2027.

AUSTRAC publishes a conveyancer starter kit for non-lawyer conveyancers who handle client funds only for real estate transactions and meet the other suitability criteria.

AUSTRAC had 1,600 enrolments in this category as at 17 September 2026.

If you should be enrolled and are not

AUSTRAC can issue an infringement notice of $21,840 for a company or $4,368 for an individual per contravention (60 or 12 penalty units at $364), or seek a civil penalty of up to $36.4M (body corporate) or $7.28M (individual) per contravention. Since 28 August 2026 AUSTRAC has been issuing section 167 notices to businesses that appear to provide designated services without enrolling.

Questions

Do conveyancers need to enrol with AUSTRAC?
Yes. A conveyancer who assists a client to plan or execute a real estate transaction provides a designated service under table 6, item 1 of section 6 of the AML/CTF Act. That is the core of conveyancing work, so in practice every conveyancing practice acting in property transactions must enrol, and must do so within 28 days of first providing the service.
When is the enrolment deadline?
Enrol within 28 days of first providing a designated service (s 51B). For a business already providing the service on 1 July 2026, that was 29 July 2026.
Is there a starter kit for conveyancers?
AUSTRAC publishes a conveyancer starter kit for non-lawyer conveyancers who handle client funds only for real estate transactions and meet the other suitability criteria.

Related

Sources

Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.