Does Customer due diligence (KYC) on every customer apply to conveyancers?
A computed answer from the Rules Mate applicability engine, with the exact condition, the outcome for every structure and size, and the primary source.
Short answer: Yes
Yes. This obligation applies to conveyancers whatever their structure or size. The deciding fact: Tranche 2 industry (Conveyancers) — AML/CTF reporting entity from 1 July 2026.
The obligation in brief
Customer due diligence (KYC) on every customer. Reporting entities must collect and verify customer identification information before providing a designated service. For non-individuals, beneficial owners (≥25% control or ownership) must be identified.
Trigger: Onboarding a customer for a designated service.
Why conveyancers get a different answer
Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 27 of those industries the answer for "Customer due diligence (KYC) on every customer" is no. Conveyancers is one of the 8 where the answer is different: yes.
The deciding fact for conveyancers: Tranche 2 industry (Conveyancers) — AML/CTF reporting entity from 1 July 2026.
About the industry: Licensed conveyancers effecting property transfers and settlements via PEXA.
Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires an AML/CTF designated service).
Answer by business structure and size
Each cell is the engine's outcome for a business in conveyancers with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.
| Structure | No employees | 1–5 employees | 6–19 employees | 20–99 employees | 100–499 employees | 500+ employees |
|---|---|---|---|---|---|---|
| Sole trader | Yes | Yes | Yes | Yes | Yes | Yes |
| Partnership | Yes | Yes | Yes | Yes | Yes | Yes |
| Trust | Yes | Yes | Yes | Yes | Yes | Yes |
| Pty Ltd company | Yes | Yes | Yes | Yes | Yes | Yes |
| Public company | Yes | Yes | Yes | Yes | Yes | Yes |
| Not-for-profit (unregistered) | Yes | Yes | Yes | Yes | Yes | Yes |
| Registered charity | Yes | Yes | Yes | Yes | Yes | Yes |
| Super fund | Yes | Yes | Yes | Yes | Yes | Yes |
| Foreign company | Yes | Yes | Yes | Yes | Yes | Yes |
Designated services that catch conveyancers
| AML/CTF Act reference | Service | Customer for due diligence |
|---|---|---|
| s 6 table 6 item 1 | Assisting a person to plan or execute a real estate transaction (not under a court order) | The person assisted |
| s 6 table 6 items 2–4 | Assisting 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 financing | The person assisted |
- 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.
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.
What the obligation requires
- When due
- Before providing the designated service. Ongoing for customer relationships.
- Evidence to keep
- KYC records (identity documents, beneficial ownership), PEP/sanctions screening evidence, EDD documentation.
- Maximum penalty
- Each unverified customer can be a separate contravention — up to $36.4M (body corporate) or $7.28M (individual), maximum per contravention
- Regulator
- AUSTRAC
- Jurisdiction
- Commonwealth (national)
Other obligations where conveyancers differ from the norm
- Designate an AML/CTF Compliance Officer: Yes
- Detect + enhance due diligence on Domestic + Foreign PEPs: Yes
- Enrol with AUSTRAC as a reporting entity: Yes
- Maintain a written AML/CTF program: Yes
- Suspicious matter, threshold, and IFTI reporting to AUSTRAC: Yes
- Independent review of AML/CTF program: Yes
- All 11 answers for conveyancers
Other industries with a non-default answer
Questions
- Does Customer due diligence (KYC) on every customer apply to conveyancers?
- Yes. This obligation applies to conveyancers whatever their structure or size. The deciding fact: Tranche 2 industry (Conveyancers) — AML/CTF reporting entity from 1 July 2026.
- Is the answer the same for every industry?
- No. For 27 of the 35 industries Rules Mate maps, the answer is no. Conveyancers is one of 8 industries with a different answer.
Related
Sources
- AUSTRAC: official source
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006
- AUSTRAC guidance
- AUSTRAC: Professional designated services (table 6)
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (compilation in force 1 Jul 2026)
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.