Designated services · 1 of 13 · Table 6, item 1

Conveyancing, and where AML/CTF touches it

You already know how a conveyance runs. This is the same transaction with one question added: at which step does the AML/CTF Act apply, and what do you have to do about it?

All thirteen designated services

Start here

What conveyancing is

The title moves, not the building

Conveyancing is the work of moving a legal interest in property from one person to another. Most often that is a house: the seller owns it, the buyer pays for it, and somebody has to do the paperwork that makes the change official at the land registry.

New South Wales is the only state that defines the work itself in its licensing statute, and the definition is worth reading because it is wider than most people expect.

THE DEFINITION — “CONVEYANCING WORK”

“legal work carried out in connection with any transaction that creates, varies, transfers or extinguishes a legal or equitable interest in any real or personal property, such as the sale of land or business”

Conveyancers Licensing Act 2003 (NSW), s 4. The same section adds the work of preparing the documents that give effect to the transaction, and work “consequential or ancillary” to it.

Who is allowed to do it

This varies by state, and it changes who carries the AML obligation. In most places a licensed conveyancer can do the work without being a lawyer. In Queensland no such licence exists — conveyancing there is legal practice, and only a solicitor may do it.

Who may carry out conveyancing, by jurisdiction

State	Who may do the work	Under
NSW	Licensed conveyancer, or a solicitor	Conveyancers Licensing Act 2003
VIC	Licensed conveyancer, or a solicitor	Conveyancers Act 2006
QLD	Solicitor only — no conveyancer licence exists	Legal Profession Act 2007
SA	Registered conveyancer, or a solicitor	Conveyancers Act 1994
WA	Settlement agent, or a solicitor	Settlement Agents Act 1981
TAS	Licensed conveyancer, or a solicitor	Conveyancing Act 2004

Queensland settled 196,000 properties in FY25, more than any other state — and every one of those settlements was handled by a law firm, because Queensland has no conveyancer licence.

Conveyancing work is wider than the AML service

This is the first cross-check worth making, and it saves work. Your licence covers conveyancing work, which reaches leases, mortgages, personal property and advice. The AML/CTF designated service is narrower: it is only about transactions to sell, buy or otherwise transfer real estate. Plenty of what you do every week is the first and not the second.

The same matter, under two different definitions

The matter	Conveyancing work?	Designated service?
Selling or buying a house or land	Yes	Yes — item 1
Transferring title between related parties	Yes	Yes — item 1
Granting or registering a lease	Yes	No — no sale, purchase or transfer
Refinancing a mortgage, same owner	Yes	No — the interest does not change hands
Sale of a business, no land involved	Yes	No — item 1 is real estate only
Advising on an easement over land already owned	Yes	No — no live transaction
Transfer ordered by a court or tribunal	Yes	No — excluded by item 1(b)

The right-hand column is what decides whether the AML/CTF Act applies to that matter. The left-hand column decides whether you need a licence to do it.

The size of it

Three quarters of a trillion dollars, every year

Conveyancing is the largest designated service brought in by Tranche 2 by value. In the 2025 financial year, 722,000 properties settled across the five mainland states, worth $726.6 billion between them. Queensland alone settled 196,000 — more than any other state.

Settled in FY25

722,000

Properties settled across the five mainland states, up 3.2% on FY24

Value settled

$726.6b

Aggregate value of property settled in FY25, up 9.4% year on year

Mean dwelling price

$1.10m

Australian mean residential dwelling price, June quarter 2026

Captured since

1 Jul 2026

Conveyancing became a designated service under Table 6, item 1

What actually happens

Ten steps, and the service starts at step two

A standard residential conveyance in Australia runs roughly like this. The designated service does not begin when someone walks in the door. It begins when you start work on a transaction that buyer and seller have agreed.

The designated service begins when you start work on an agreed transaction — at the contract, not when funds arrive. Money moves twice after that: the deposit, then the balance at settlement.

A residential conveyance, start to finish

Step	Who does it	What moves
1. Agreement	Buyer and seller agree a price, usually through the agent	Nothing yet — no contract exists
2. Contract prepared	Seller’s conveyancer or lawyer drafts the contract of sale	← The designated service starts here
3. Exchange	Both parties sign; the buyer pays the deposit	Deposit into the agent’s or conveyancer’s trust account
4. Identity verified	Both conveyancers verify their own client under the ARNECC VOI Standard	Certified copies of ID, retained 7 years
5. Searches	Buyer’s side orders title, rates, land tax and planning searches	Title search from the state land registry
6. Finance	Buyer’s bank values the property and issues unconditional approval	Loan documents signed and returned
7. Duty assessed	Transfer duty calculated and lodged with the state revenue office	Duty paid, or an exemption claimed
8. Settlement booked	Both sides create a workspace in PEXA and agree the figures	Settlement statement, adjusted for rates
9. Settlement	Funds and title transfer simultaneously in the PEXA workspace	Balance of price moves; title changes hands
10. Registration	The transfer registers automatically at the land registry	New title issued in the buyer’s name

A typical agreed-price residential sale. Off-the-plan, auction and deceased-estate transfers vary at steps 3, 7 and 9.

Step 3 is the one that matters most for risk. The deposit lands in a trust account — yours or the agent’s — and at step 9 the balance moves. Handling someone else’s money in a property transaction is the thing the regime was extended to reach. It is also why the obligation cannot be satisfied by looking only at the person in front of you: the question is whose money this is, and where it came from.

A conveyancer stands behind a counter with a hand on a locked box, a buyer on one side and a seller on the other — Money held for someone else, in a transaction

Who is in the transaction

Nine parties, and four of them are reporting entities

One house sale now involves four separate reporting entities, each doing its own customer due diligence on its own client. The banks have done this since 2006. The two conveyancers and the agent started on 1 July 2026.

Who touches a residential sale

Party	What they do	AML/CTF status
Buyer	Pays the price, takes the title	Your customer, if you act for them
Seller	Transfers the title, receives the price	Your customer, if you act for them
Buyer’s conveyancer or lawyer	Searches, settles, registers the transfer	Reporting entity — item 1
Seller’s conveyancer or lawyer	Drafts the contract, discharges the mortgage	Reporting entity — item 1
Real estate agent	Markets the property, brokers the sale, holds the deposit	Reporting entity — Table 5, item 1
Buyer’s bank	Lends and takes a mortgage	Already regulated since 2006 — Table 1
Seller’s bank	Discharges the existing mortgage	Already regulated since 2006 — Table 1
State land registry	Registers the transfer, issues the new title	Not a reporting entity
State revenue office	Assesses and collects transfer duty	Not a reporting entity

Note what this means in practice: your client will be verified more than once, by you and by their bank, and possibly by the agent as well. That is not duplication to be tidied away. Each reporting entity owes the obligation for its own customer, and cannot discharge it by assuming someone else did the work.

The part most guides get wrong

You already verify identity. This is not that.

Two people seated across a desk, one holding a magnifying glass over a document between them — Checking who is sitting opposite you

VOI

Verification of Identity. The identity check conveyancers and property lawyers have done for years before lodging a dealing electronically. The standard is set by ARNECC — the Australian Registrars’ National Electronic Conveyancing Council — and applied through each state’s Participation Rules. Its purpose is narrow: to satisfy the land registry that the person signing the transfer is the person entitled to sign it.

So the honest question is not how to check a driver licence. You have done that for years. It is what customer due diligence adds to the VOI you already do.

The short answer: VOI answers one question, and customer due diligence asks several more. They overlap at exactly one step.

The two overlap at one step and diverge everywhere else. A completed VOI does not finish your customer due diligence, and doing CDD does not by itself satisfy the VOI Standard.

VOI and customer due diligence, side by side

	ARNECC VOI	AML/CTF customer due diligence
What it is for	Proving the person signing is who they say they are, for the land registry	Understanding who the customer is and what their money laundering risk is
Who requires it	ARNECC, through the state Participation Rules	AUSTRAC, through the AML/CTF Act and Rules
Identity documents	Yes — the VOI Standard sets the document categories	Yes — and the Rules set their own KYC minimums
Beneficial ownership	No	Yes — who actually owns or controls a company, trust or SMSF buyer
Risk assessment of the customer	No	Yes — you must assess and record the customer’s ML/TF risk
PEP and sanctions screening	No	Yes
Source of funds or wealth	No	In higher-risk cases, yes
Ongoing monitoring	No — VOI is done once, for the dealing	Yes — for the life of the business relationship
Applies to	The signer of the registry instrument	The customer of the designated service

Two practical consequences follow. First, a completed VOI does not finish your CDD — you still need the KYC information the Rules require, a recorded risk assessment of the customer, and PEP and sanctions screening.

Second, it does not work the other way either. Doing CDD does not automatically satisfy the VOI Standard, because the two are set by different bodies for different purposes. Using your CDD process may count towards taking reasonable steps under the Participation Rules, but it is not a substitute.

Where the two overlap, one identity check can serve both — but the record has to show you met each standard, not that you did something in the middle.

Are you providing it?

Does the work advance the transaction, or only influence it?

That is AUSTRAC’s own test, and it is the most useful line to hold on to. Work that moves the transfer forward is caught. Work that shapes someone else’s decision about it is not. Most matters answer themselves once the question is put that way — and the ones that do not are the ones worth a file note.

A person standing before a row of identical doorways, one of them highlighted — Which of these is a designated service

Worked examples, from AUSTRAC’s professional-services guidance

The work	Caught?
Preparing the contract of sale once buyer and seller have agreed a price	Caught
Acting for the buyer or the seller to plan or execute the transfer	Caught
Conveyancing to give effect to a binding financial agreement between separating parties	Caught
Doing the conveyance for a family member, one-off, for no fee	Caught — if it is connected to your business
Advising the conveyancer on the legal effect of terms in the contract	Not caught — influences, does not advance
Acting on a transfer made under a court or tribunal order	Not caught — expressly excluded by item 1(b)
Advising on rights over a property already bought and settled	Not caught — no live transaction

The fourth row surprises people. A one-off conveyance for a relative, done for nothing, is still a designated service if it is connected to the conduct of your business. There is no small-business exemption and no minimum number of matters.

What actually gets checked

Eight checks, and what has to survive in the file

This is the part that actually takes time in a matter. For each check: what the law asks for, how it is usually done, and what has to be left in the file afterwards. The last column matters most — the obligation is not only to do the check, but to be able to show later that you did.

The dashed line is a gate. Initial customer due diligence belongs on the near side of it, before you start work on the transfer.

The checks, how they are done, and what you keep

The check	What is required	How it is usually done	What stays in the file
Identify the customer	Collect the customer’s full name and date of birth, and their residential address	Driver licence or passport, captured in person or through a digital check	The information collected, and how it was verified
Verify the identity	Satisfy yourself on reasonable grounds that the customer is who they claim to be	Document check against the issuing source, or an electronic verification service	What was checked, against what, on what date
Look through a company, trust or SMSF	Identify each beneficial owner — generally anyone owning or controlling 25% or more	ASIC company extract, trust deed, or the SMSF’s member records	Who the beneficial owners are, and the document you relied on
Understand the purpose	Understand the nature and purpose of the business relationship	Usually clear from the matter itself: an owner-occupier buying a home	A note of the purpose where it is not obvious from the file
Screen for PEPs and sanctions	Determine whether the customer is a politically exposed person, and screen against the DFAT Consolidated List	A screening tool, or a manual search of the DFAT list	The screening result and its date — including a clear result
Rate the customer’s risk	Assess and record the ML/TF risk the customer presents	Applying your program’s risk factors: customer, service, channel, country	The rating, and the reasons for it
Ask about source of funds	In higher-risk cases, establish source of funds or source of wealth	Often unnecessary — a bank-financed purchase explains itself	The explanation, and any evidence you asked for
Keep watching	Monitor the relationship for as long as it lasts	Reviewing when something changes: a new party, a redirected payment	What you reviewed, when, and what you concluded

Records are kept for 7 years. Which checks apply, and how far each goes, depends on the customer’s risk and on your own AML/CTF program — a low-risk owner-occupier and an offshore-trust buyer do not get the same treatment.

A person drawing one highlighted file from a wall of cabinet drawers while three colleagues look on — Seven years later, the file either shows it or it does not

Two of these are where conveyancing practices are spending unexpected time. Looking through a company or trust buyer is the first: a single settlement with a corporate buyer and a trust seller can mean identifying six or more individuals, none of whom sign anything at the registry.

Recording the risk rating is the second. It feels like paperwork for its own sake until a notice arrives, at which point the file either shows the judgement you made or it does not. See customer due diligence for the four types and which AUSTRAC form fits which customer.

The provision itself

Table 6, item 1, in the Act’s own words

THE ACT — s 6(5B) TABLE 6, ITEM 1

“assisting a person in the planning or execution of a transaction, or otherwise acting for or on behalf of a person in a transaction, to sell, buy or otherwise transfer real estate, where: (a) the service is provided in the course of carrying on a business; and (b) the sale, purchase or other transfer is not pursuant to, or resulting from, an order of a court or tribunal”

Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), s 6(5B) table 6, item 1 — Compilation No. 62 (C2026C00274). The customer is “the person”.

Read the two conditions at the end. Paragraph (a) is why an unpaid favour still counts, so long as it is connected to your business. Paragraph (b) is why a court-ordered transfer does not.

Item 1 is also the only item in Table 6 the Rules single out: the delayed customer due diligence and reliance provisions for real estate transactions reach item 1 and nothing else. See the nine Table 6 services in full for how the rest compare, and customer due diligence for what the four types require.

The thirteen designated services

One article for each service you can select when you enrol

13 of 13 written so far. The rest are in progress.

Professional services

Conveyancingyou are here
Every step of a settlement, and how CDD differs from the VOI you already do.
Table 6, item 1
Selling a business
When a company or trust changes hands.
Table 6, item 2
Client money
Holding or controlling someone else’s money or property in a transaction.
Table 6, item 3
Equity and debt financing
Raising money for a company or legal arrangement.
Table 6, item 4
Shelf companies
Selling or transferring a company created to be sold.
Table 6, item 5
Company and trust formation
Creating or restructuring a company, trust or partnership.
Table 6, item 6
Director and trustee roles
Acting as, or finding someone to act as, a director, trustee or attorney.
Table 6, item 7
Nominee shareholders
Holding shares in your name for somebody else.
Table 6, item 8
Registered office
Letting a client use your address as their registered office.
Table 6, item 9

Real estate

Real estate agents
The agent’s customer is both sides of the deal — and the two sides start at different moments.
Table 5, item 1
Property developers
Selling your own stock with no agent in between, and why that changes who the customer is.
Table 5, item 2

Bullion and precious goods

Bullion
Gold, silver, platinum and palladium, and the $5,000 exemption.
Table 2, item 1
Jewellers and dealers
Why the $10,000 line is about how the customer pays, not what they buy.
Table 2, item 2

Sources

Where every figure here comes from

Data as at 27 September 2026.

Conveyancers Licensing Act 2003 (NSW), s 4 — “Conveyancing work” · NSW legislation · Current in force
The definition quoted at the top of this page.
Conveyancer licences — who may carry out conveyancing in NSW · NSW Government · Current guidance
The licensing requirement behind the NSW row of the jurisdiction table.
Legal Profession Act 2007 (Qld) · Queensland legislation · Current in force
Queensland has no conveyancer licence; conveyancing is legal practice and requires a practising certificate.
Property Insights FY25 — settlement volumes and values · PEXA Group · FY25 (Jul 2024 – Jun 2025)
722,000 properties settled across NSW, VIC, QLD, WA and SA; $726.6 billion aggregate value; Queensland 196,000. PEXA covers over 95% of national property transactions.
Total Value of Dwellings · Australian Bureau of Statistics · June quarter 2026
Mean price of Australian residential dwellings $1,100,400.
Anti-Money Laundering and Counter-Terrorism Financing Act 2006, s 6(5B) table 6 · Federal Register of Legislation · Compilation No. 62 (C2026C00274)
Item 1, quoted verbatim on this page.
Professional designated services · AUSTRAC · Guidance, current at Sep 2026
The directly-advance versus merely-influence distinction, and the treatment of one-off and unpaid services.
Verification of Identity Standard · ARNECC · Guidance note, July 2026
The VOI Standard as it applies to electronic conveyancing.
ARNECC requirements for Verification of Identity and Client Authorisation · Legal Practitioners’ Liability Committee · Practice resource
How VOI sits in practice, and why CDD does not automatically satisfy the VOI Standard.
AML/CTF program starter kits · AUSTRAC · Conveyancer kit, v1.1 June 2026
The sector kit for conveyancing practices.
AML/CTF Resource Hub · Australian Institute of Conveyancers · Current
The profession’s own collected guidance. Listed because it is where conveyancers are being pointed, not as authority for anything on this page.

Before you rely on this

This content is general information only. It is not legal, financial or compliance advice. Organisations should check AUSTRAC guidance, legislation, their own AML/CTF Program and professional advice where needed.

Whether a particular matter is a designated service depends on its own facts. Nothing here decides that for you.
The ten-step settlement above is a typical agreed-price residential sale. Auctions, off-the-plan purchases, deceased estates and related-party transfers all differ.
The jurisdiction table describes who may carry out conveyancing, not who is a reporting entity. Reporting-entity status follows the designated services provided.
Figures are as at 27 September 2026 and come from the sources listed above. Check them against the source before relying on them.

Lex-AML supports compliance workflows and record keeping. It does not provide legal advice, does not guarantee compliance, and does not replace professional judgement or advice from a qualified AML/CTF adviser or legal professional.

Why a technology company writes this

GetPost Labs is a technology company. We are not a law firm and not a compliance adviser, and this page is not a substitute for either.

We build Lex-AML. To build it properly we had to understand these obligations the way the people carrying them do, so we researched them with small and medium practices across the affected sectors — how the work actually runs, where the law lands inside it, and which questions were hardest to get a straight answer to. Publishing what we found is how we check that we have understood a requirement before we build for it.

That understanding is also what we bring to a conversation. No two practices run a matter the same way, and tooling that assumes one way of working fits almost nobody. We would rather start from how you already work — your intake, your file, your sign-off, the software you already pay for — and shape the compliance work around that than hand you a process and ask you to adopt it.

So this is an offer of capability, not a pitch. If Lex-AML turns out to fit your practice, we would like to work on it with you. If it does not, what is written on this page stands on its own, and every source it rests on is listed above so you can check it yourself.