Identify the service start
The moment the service starts determines when CDD must be complete. AUSTRAC's real-estate guidance explains the timing for the parties and any delayed CDD, including the 28-day and pre-settlement rules for real estate work. Record the analysis so the file shows why the timing was lawful.
- Confirm when the conveyancing designated service starts on the file
- Record the scope decision and the parties it covers
- Apply the delayed-CDD rules only where they permit the timing
- Check the settlement deadlines against the CDD requirements
Verify the parties
A property transaction often involves a buyer's agent, a funder and a corporate purchaser. The party list should be explicit and the CDD file should show who was checked, when and from which source.
- Identify and verify the vendor or transferor and purchaser or transferee
- For entity purchasers, map beneficial owners and controllers
- Identify funders, guarantors and other parties the program requires
- Screen for PEPs, sanctions and adverse media
- Complete the identity work before settlement
Settlement and source of funds
The settlement window is where laundering appears: funds from an unrelated entity, rapid changes to the purchaser, or a 'gift' that cannot be traced. The conveyancer's source-of-funds discipline should be connected to the settlement checklist.
- Review the source of funds at the risk tier the matter requires
- Check settlement funds against the purchase price and the parties
- Escalate third-party payments and unexplained funding
- Reconcile controlled money with documented authority
- Lodge SMRs within the deadline and protect SMR-related information
Records and review
The conveyancing file is the AML record: contract, parties, verification, screening, source of funds, settlement and any reports. A complete file demonstrates the control; a folder of documents without decisions does not.
- Retain the scope decision, party CDD, screening, settlement and reporting records
- Keep the file structured so an examiner can follow the matter
- Deliver training on the settlement-specific triggers
- Test the workflow against a controlled matter
Official sources
Use these primary AUSTRAC pages to confirm the current rules and apply them to your circumstances.
Frequently asked questions
When does the conveyancing designated service start?
The start depends on the service and the statutory timing rules. Identify the triggering step on the file and apply the CDD and delayed-CDD provisions to that point.
Which parties must be verified?
The vendor or transferor and purchaser or transferee, with beneficial owners for entities, plus any other parties the program requires for the matter and risk.
Can settlement proceed before CDD is complete?
Only where a permitted delayed-CDD or transitional rule applies and its conditions are met. Otherwise initial CDD must be complete before the designated service is provided.
What should the conveyancing AML file contain?
The scope decision, party verification, screening results, risk rating, source-of-funds evidence, settlement records and any reporting decisions, retained for the required period.
Put it into practice
Cassandra AML turns these obligations into a working system: designated-service decisions, customer due diligence, screening, monitoring and reporting records — hosted in Sydney, free to start.
This guide is general information for Australian professionals. It is not legal advice and does not replace the AML/CTF Act, the AML/CTF Rules or AUSTRAC guidance. Confirm your specific obligations with AUSTRAC or a qualified legal adviser. See our editorial and correction standards.