Every conveyancing practice provides a Tranche 2 designated service. From 1 July 2026, customer due diligence on the parties to each transaction, beneficial-ownership identification for corporate or trust buyers, source-of-funds enquiries on deposits, and Suspicious Matter Reports to AUSTRAC sit alongside the existing state-licensing regime. This page covers the practical implications for residential, commercial, and off-the-plan conveyancing.
Trust account operations are already supervised by the state regulator. Tranche 2 adds an AML/CTF program, customer due diligence on the parties (typically the buyer, often the seller), beneficial-ownership identification when a corporate or trust is acquiring property, and a written SMR process. The transactional cadence of conveyancing, high volume of similar matters with predictable patterns, makes this both more straightforward to systematise than other Tranche 2 sectors and more visible to AUSTRAC if patterns deviate.
Customer due diligence at engagement: identity collection + verification via DVS, source-of-funds note on deposit and balance, sanctions screen. Most matters complete with no additional ECDD triggers.
Identify the trustee (and beneficial owners of any corporate trustee), the settlor, and the named beneficiaries to the extent ascertainable. Document the rationale for using a trust structure.
Enhanced customer due diligence: source of wealth and source of funds, senior-management sign-off, and tighter ongoing monitoring through to settlement. FIRB clearance does not satisfy AML/CTF obligations, they run in parallel.
Source-of-funds enquiry on the depositor. If unable to verify or if the pattern is inconsistent with the buyer profile, treat as an SMR candidate, assess within 3 business days.
Every conveyancing practice must enrol. Enrolment opens 31 March 2026. The principal of the practice is typically the registered reporting entity.
Part A risk assessment + Part B customer identification, both tailored to conveyancing service mix (residential vs commercial vs off-the-plan). Senior-management approved and annually reviewed.
Identity + verification on the buyer at engagement. Similar obligations frequently apply to the seller depending on the service framing. Documentation lives in the matter file.
Trace through corporate or trust buyers to the controlling natural persons. Document the verification source and any difficulty in identification.
Document the source of the deposit and balance funds. Third-party payments require additional identification of the depositor.
Suspicious Matter Reports filed to AUSTRAC within 3 business days of forming a suspicion. Tipping-off the customer is prohibited.
Annual compliance report due 31 March covering the previous calendar year. Customer identification + transaction records retained 7 years.
Captures customer due diligence at matter intake (no extra workflow for the conveyancer), maintains the beneficial-ownership register as entities change, monitors trust-account flows for suspicious patterns, and prepares the AUSTRAC annual report from the audit trail. Runs inside your tenancy, client identification records and matter files stay where they already live.
Every claim on this page draws on the AUSTRAC published guidance for Tranche 2 entities, plus the sector-specific commentary listed below.
Twenty-five questions, an inline readiness percentage, and a personalised PDF report mapped to conveyancers obligations. Free, no commitment, no demo required.
This assessment provides general information about Tranche 2 obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). It is not legal advice. For your specific obligations, consult an AML/CTF compliance professional.