Set-up (once)
- Enrolled with AUSTRAC.
- Appointed a compliance officer.
- Adopted an AML/CTF program covering conveyancing and trust money.
- Trained staff and recorded it.
At engagement
- Identified and verified the client (VOI plus the AML fields: beneficial owners, purpose, risk rating, review date).
- Asked about source of funds where the risk is higher.
- Recorded who verified and when.
At settlement
- Checked the funds flow matches the file: payer, amounts, accounts.
- Reported any cash of AU$10,000 or more within 10 business days.
- Escalated anything that does not fit to the compliance officer; reported a suspicion within 3 business days.
At file close and after
- Kept identification and transaction records for 7 years.
- Reviewed the program yearly; lodged the annual compliance report.
Questions people ask
- Where does the AML record live?
- Alongside the matter file, in a system that keeps history and cannot lose the record when the matter is archived.
Sources
Official AUSTRAC guidance this page was checked against. The date is when we captured the page; AUSTRAC may have updated it since.
- Professional designated services · AUSTRAC, captured 14 Sept 2026
- Real estate designated services · AUSTRAC, captured 12 Sept 2026
- Record keeping checklist · AUSTRAC, captured 17 May 2026
This guide is general information for solicitors, conveyancers, settlement agents, not legal advice. Check AUSTRAC's current guidance for your situation.