Conveyancers
AML/CTF for conveyancers: client checks alongside VOI
Assisting with a real estate transfer can be a designated service. Your AML checks sit alongside, not instead of, your existing verification of identity rules.
Under AUSTRAC's professional designated services guidance, taking active steps to assist a client with a real estate transfer can be a designated service, regardless of whether you are a conveyancer, a lawyer or another professional. If you provide that service, obligations have applied since 1 July 2026.
Conveyancers already verify identity for electronic conveyancing and land registry purposes. Those verification of identity (VOI) requirements are separate rules with their own standards. An AML/CTF identity check does not automatically satisfy them, and a VOI does not automatically satisfy AML/CTF customer due diligence. AML CDD also covers beneficial owners, persons acting on behalf, the nature and purpose of the matter, PEP and sanctions checks and a customer risk rating.
Matters involving companies, trusts and SMSFs need extra care, because you need to identify the individuals who ultimately own 25% or more, or who otherwise control the entity. Powers of attorney and other representatives need their authority confirmed.
Plan the order of steps at matter opening so that neither process holds up settlement.
Scope
What is and isn't usually in scope.
Services that can be designated services
- Assisting a client with the sale, purchase or transfer of real estate
- Receiving, holding or controlling client funds to advance the transfer, subject to exceptions
Not automatically captured
- General information that does not take active steps to advance a transaction
- Meeting your separate VOI obligations, which AML checks do not automatically satisfy
Apply AUSTRAC's guidance to each matter type, and check your separate VOI rules with your regulator or registry. Not sure? Try the readiness checker.
Example workflow
A practical onboarding sequence.
- 1
Open the matter
Record the parties, the property and whether the matter is a designated service.
- 2
Run your VOI as usual
Follow your existing VOI standard. Do not treat the AML check as a replacement.
- 3
Run the AML check
Send an InvestPass link for each client. For entities, add each beneficial owner.
- 4
Confirm representatives
Check anyone acting under a power of attorney or other authority, and record the authority.
- 5
Review funds and risk
Note the source of funds where risk requires it, and escalate unusual payments or potential sanctions matches.
- 6
Keep records
CDD records are generally kept for 7 years after the relationship ends or the last occasional transaction.
This is an example only. Adapt it to your own AML/CTF policies.
Identity check vs program
A check is one step, not the whole job.
An InvestPass check helps with one part of customer due diligence: verifying identity and gathering ownership details. It does not by itself make you compliant. You still need your ML/TF risk assessment, AML/CTF policies, a compliance officer, PEP and sanctions handling, ongoing due diligence, reporting and record keeping. AUSTRAC states that a digital identity check alone is not full AML/CTF compliance.
When to check
Moments that usually need a check.
- Opening a new matter
- A party to the transfer is a company, trust or SMSF
- Someone is acting under a power of attorney
- Funds are coming from an unexpected source
Individual check
ID verification, face match and AML screening for each client.
Company check
Company details, directors and owners in one go.
Trust and SMSF check
Trustee, deed and beneficial owners for trusts and super funds.
Good to know
Tips for your team.
- Run the AML check at matter opening. It does not replace your separate VOI step under conveyancing rules.
- Add each owner to an entity check so nobody is missed.
General information only, not legal advice. Check your own obligations with AUSTRAC guidance or a qualified adviser.
Pricing
Pay per check. No monthly fee.
Individual Verification
FeaturedIndicative, to be confirmed
$20per person · GST included
Identity and AML screening for one person.
- Identity verification
- ID document and liveness
- PEP, sanctions and watchlists
- Risk assessment
Entity Verification
Indicative, to be confirmed
$40per entity · GST included
Company, trust or SMSF verification.
- ABN / ACN and business details
- Directors, trustees and shareholders
- Trust deed collection
- Entity screening
Beneficial Owner Verification
Indicative, to be confirmed
$20per owner · GST included
Each beneficial owner of an entity: owns 25% or more, or otherwise controls it.
- Identity verification
- PEP and sanctions screening
- Linked to the entity report
Indicative, to be confirmed. Prices in AUD, GST included.
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