AUSTRAC Tranche 2: what conveyancers need to know before 1 July 2026.
TL;DR
- From 1 July 2026, conveyancers performing certain designated services (handling property settlements, acting on a real-property transfer, operating a trust account for the transaction) become reporting entities under the AML/CTF Act 2006 (Cth).
- Five obligations attach: enrol with AUSTRAC before you start providing the designated service; write an AML/CTF program (Part A risk assessment + Part B customer due diligence); appoint an AML Compliance Officer; run customer identification and verification (CDD) on both buyer and seller sides; report suspicious matters (SMRs) and threshold transactions of AUD 10,000 or more (TTRs).
- Record-keeping: seven years. Conveyancers have trust-account exposure every transaction, which makes the threshold-transaction reporting obligation particularly load-bearing.
- AUSTRAC enrolment opened 31 March 2026. You cannot wait until 1 July.
- Ironbark checks an ABN against ABR, ASIC, AUSTRAC, DFAT sanctions, AFSA insolvency, and the Federal Court in seconds. $0.49 per check, credits never expire. Free tier: 10 checks per month.
What changes on 1 July 2026
Tranche 2 brings conveyancers into the reporting-entity regime.
The AML/CTF Amendment Act 2024 (Cth) extends the list of 'designated services' in the AML/CTF Act 2006 (Cth) to cover real-property conveyancing and settlement services effective 1 July 2026. You are captured when you provide the service in the course of carrying on a conveyancing practice, not as an isolated favour.
Trust-account movements trigger threshold transaction reports.
Every settlement that moves AUD 10,000 or more through your trust account is a reportable threshold transaction. A TTR must be lodged with AUSTRAC within 10 business days. Aggregation rules apply to deliberately structured payments across multiple settlements for the same parties.
Suspicious matter reporting is active.
If a transaction gives rise to reasonable grounds to suspect a connection with a serious offence (fraud, money laundering, tax evasion, terrorism financing) an SMR must be lodged within three business days (24 hours if the suspicion relates to terrorism financing). Structuring, unusual funding sources, and third-party payments are common SMR triggers in conveyancing.
Customer due diligence runs both sides.
You identify and verify both the buyer and the seller where you act on either side. For complex parties (discretionary trusts, companies, overseas-incorporated entities) enhanced customer due diligence applies, which includes beneficial-owner resolution where ownership or control is non-obvious.
Who is in scope
The Tranche 2 cohort covers ~7,000 reporting entities in the conveyancers profession. Approximately 70% are sole practitioners or micro-firms (1–3 staff).
Based on combined state-licensed conveyancer and settlement-agent counts across NSW, VIC, QLD, WA, SA, ACT, TAS and NT (licensing registers as at 2024). Independent conveyancing remains small-firm dominant.
Independent conveyancers with a state licence
State-licensed conveyancers operating in NSW, VIC, QLD, WA, SA, ACT, TAS and NT who act on property transfers for clients. Solicitor-conveyancers are covered under the lawyer Tranche 2 rules instead; see /tranche-2/lawyers.
Settlement agents (WA)
WA settlement agents licensed under the Settlement Agents Act 1981 (WA) performing real-property transfers are captured. The designated service is the settlement itself.
Conveyancing firms of any size
Sole practitioners, partnerships, and multi-licensee firms are all captured. Scale does not affect applicability; it affects the risk-based shape of the AML/CTF programme.
The designated services
An entity is captured only in respect of designated services it provides. Services the AML/CTF Amendment Act 2024 (Cth) adds to cover conveyancers include:
- Acting on a real-property transfer for a buyer or seller
- Operating a trust account through which settlement funds move
- Witnessing or certifying transaction documents where part of a designated service
- Handling stamp-duty and registration funds on behalf of a party to the transfer
What you must do
Five obligations attach to every reporting entity. The AML/CTF program scales to the nature, size, and complexity of the business. A sole practitioner and a mid-firm follow the same framework at different scales.
Enrol with AUSTRAC
Before you commence providing a designated service after 1 July 2026, enrol your business via the AUSTRAC Online portal. Enrolment is free. AUSTRAC enrolment opened 31 March 2026; processing takes several weeks, so do not defer this.
Write an AML/CTF program (Part A + Part B)
Part A is a risk assessment of the business (customers, services, channels, jurisdictions). Part B covers the customer due-diligence procedures that flow from the risk assessment. The program must be in writing, approved by the governing body, reviewed periodically, and provided to AUSTRAC on request.
Appoint an AML Compliance Officer (AMLCO)
The AMLCO must be an employee or partner at management level, fit and proper, able to have the AML/CTF program amended, and able to discharge reporting obligations. The role cannot be outsourced to an external consultant. Consultants may advise and draft, but the AMLCO sits inside the reporting entity.
Run customer identification and verification (CDD)
Identify and verify the customer before providing the designated service. Run enhanced due diligence where risk indicators are present (foreign PEPs, opaque ownership, high-risk jurisdictions). Re-verify on trigger events. Record each CDD step with source documents, dates, and the identity of the staff member who ran the check.
Report SMRs, TTRs, and keep records
Lodge a suspicious matter report (SMR) within three business days of forming a suspicion on reasonable grounds (24 hours for suspected terrorism financing). Lodge a threshold transaction report (TTR) within 10 business days for any transaction involving AUD 10,000 or more. Keep CDD, transaction, and report records for seven years from the date the service was provided or the customer relationship ended.
How Ironbark helps
Ironbark is an AU-native compliance check product. It is not an end-to-end AML/CTF programme. The programme, AMLCO, and reporting workflow remain the reporting entity’s responsibility. Ironbark discharges the verification component, specifically.
12-second Trust Score check against ABR, ASIC, AUSTRAC, DFAT sanctions, AFSA insolvency, Federal Court. Every sub-score source-linked and exportable as a PDF for your AML/CTF evidence file.
Add the ABN to Ironbark's portfolio monitoring. Webhook + email alert when any watched entity changes status (new insolvency, new AUSTRAC enforcement action, director disqualified, GST cancelled).
Every check and every monitoring event is stamped with source, timestamp and methodology version. Append-only audit trail sized for AUSTRAC record-keeping obligations.
Any RED or AMBER Trust Score on a settlement counter-party surfaces the contributing sub-scores (sanctions hit, external administration, director disqualification) with the source citation. Ironbark does not lodge the SMR for you (AUSTRAC Online is free), but it gives you the evidence to lodge it defensibly.
Pricing for your firm size
All prices ex-GST in AUD. Credits never expire; a PAYG check purchased in 2026 is still valid in 2028. Overage on Professional tier runs at $0.40 per screen; Business tier overage runs at $0.30 per screen.
| Firm size | Checks / month | Recommended tier | Price ex-GST |
|---|---|---|---|
| Sole practitioner | 5–40 settlements / month | Solo ($29/mo) or Solo Plus ($49/mo) | $29–$49 /mo ex-GST |
| Small firm (2–10 licensees) | 40–200 settlements / month | Professional ($99/mo, 300 checks) | $99 /mo ex-GST |
| Multi-branch firm | 200–1,000 settlements / month | Business ($249/mo, 1,000 checks) | $249 /mo ex-GST |
FAQ
If I am a solicitor-conveyancer, do I follow the lawyer Tranche 2 rules or the conveyancer Tranche 2 rules?
Follow the lawyer rules under the AML/CTF Amendment Act 2024 (Cth) as they apply to legal practitioners performing designated services. See /tranche-2/lawyers for the lawyer-specific guide.
Is every settlement a designated service?
In effect, yes. Any transfer of a real-property interest where you act for a party is captured. Non-transaction advisory work (title searches, enquiries, informal advice) is not a designated service on its own, though it may bring you into scope the moment a transaction proceeds.
How does the threshold-transaction report work when stamp duty and registration fees push the total over AUD 10,000?
The threshold is calculated on the cash movement through your trust account, not on the contract price. If AUD 10,000 or more moves through the account in connection with the transaction, the TTR obligation attaches. Most settlements above a mid-six-figure price will trigger it.
Does Ironbark replace my AML/CTF program document?
No. Ironbark is the check-and-monitor layer. Your Part A risk assessment and Part B customer due diligence procedures sit alongside. The free AUSTRAC template is a reasonable starting point; Arctic Intelligence and AML Experts AU are paid alternatives for firms that want a document drafted.
What happens if my state conveyancer association publishes its own Tranche 2 guidance that differs from yours?
Follow the state association's guidance where it is more specific than this page. This guide is a starting map; your state body's published interpretation of the Act is load-bearing for your licence.
Run a free check
10 checks per month on the free tier. No card required. Credits never expire.