Over 400 conveyancers and property lawyers logged in for our first AML/CTF Check-In, bringing questions they’ve been sitting with since the Tranche 2 deadline passed on 1 July 2026. It’s exactly why the session exists: a monthly space where a risk partner from Grant Thornton, a working conveyancer, and a triSearch compliance specialist work through the real questions coming through from the industry.
Mark Pinto, Major Account Manager at triSearch, hosted, joined by Richard Storey, Partner, Risk Consulting at Grant Thornton, and Lauren Haines, Principal Licensee and Director at The Conveyancing Group. Together they worked through five AML/CTF obligations, as well as what’s new in the triSearch Compliance Centre.
Lauren Haines put it best:
“I’ve seen a lot of conveyancers who’ve looked after clients for years suddenly feel uncomfortable about what to ask, and what track to go down.”
— Lauren Haines, Principal Licensee and Director, The Conveyancing Group
Here’s a recap of the most popular topics and questions:
A few updates went live around 1 July, and they answered a large share of the questions received.
- You can now upload a previously completed verification of identity (VOI) directly into an order, rather than sending a client a new VOI link.
- A watchlist monitoring toggle is available on PEP (politically exposed person) and sanctions screening, so you can monitor a client’s name against AML/CTF watchlists for the life of the matter.
- Add notes and documents functions let you keep a clear record on file of why you accepted an answer that might otherwise look unusual.
Verification of identity: reuse and repeat clients
Do I need to resend a VOI request every time a repeat client comes back? Not if you already hold a valid VOI for that person. Richard Storey explained that your obligations under AML/CTF are customer-based, not matter-based. If the client is the same person and there’s no reason to doubt their identity, upload the existing VOI rather than sending a new request.
What if their mobile number or email address has changed? That doesn’t affect the AML/CTF assessment. Verifying identity under AML/CTF only requires confirming name, address, and date of birth. Separate identity requirements for property transactions may treat this differently, so use your judgement if there’s any doubt about who you’re dealing with.
Can I complete a VOI myself instead of using the system’s process? Yes. You can complete a face-to-face VOI yourself and upload it, though you take responsibility for having done it correctly.
PEP, sanctions, and ongoing monitoring
Is watchlist monitoring required, or optional? It’s not required to complete onboarding, but Richard Storey recommends switching it on. A single screening is a snapshot in time. Most matters run for six weeks or longer, and monitoring alerts you if a client’s risk profile changes before settlement.
What happens once the 12-month monitoring period ends? Monitoring runs on a 12-month cycle. For matters that run longer, such as off-the-plan contracts, you may need to reorder screening to stay covered for the full period.
Source of funds, cash, and risk ratings
When do I actually need to check source of funds and source of wealth? Only when a customer is assessed as high risk, for example a foreign PEP or someone connected to adverse media. This triggers enhanced customer due diligence (ECDD). It sits in the initial order as an option because it’s part of the bundle, but it’s designed to be added on after you’ve completed your risk assessment, not run by default.
In practice, how do you get comfortable with someone’s source of funds without it feeling like an interrogation? Lauren Haines pointed out it usually comes down to a normal conversation, not a formal line of questioning.
“A lot of it comes out through general conversation. I’ll often just ask what someone does for work, so I know who I’m dealing with. If they’re out on a construction site all day, they’re probably not going to be great with admin. If they’re sitting at a desk all day, I know I can get everything out of them quite easily. You sometimes just know them already.” — Lauren Haines, Principal Licensee and Director, The Conveyancing Group
Does a client’s country of birth make them high risk? Not on its own. What matters more is where the client currently lives and generates their income. An Australian citizen or permanent resident who was born overseas isn’t automatically high risk if everything else checks out.
What actually counts as “cash” for AML/CTF purposes? Physical, folding currency. $10,000 or more in physical cash triggers a threshold transaction report (TTR) to AUSTRAC, regardless of whether anything looks suspicious. Bank transfers and shortfall funds are a separate question, and simply require enough understanding of the source to confirm it makes sense for that client.
Do I need to check family members contributing to a deposit? Only if that contributor turns out to be high risk. If a parent or family member is contributing part of the purchase price, you need to verify their identity and screen them, then apply source of funds checks only if they come back as high risk.
Companies, trusts, and beneficial ownership
For a company client, do I need to verify every shareholder? No. You verify the company as your customer and the representative giving instructions. The only extra step is for any shareholder holding more than 25 percent, who becomes an ultimate beneficial owner (UBO) and needs the same checks.
Do I need to onboard every beneficiary of a trust? Only named beneficiaries, along with the trustee. Beneficiaries who fall into a general category, rather than being named individually, don’t need to be onboarded.
What about trusts or layered company structures? More complex, and it depends on the trust deed or company structure. The approach stays the same:
- Identify who ultimately controls the asset or the money
- Apply due diligence to that person or entity
- Work up through each layer until you reach a natural person
Reporting to AUSTRAC
What if I’ve worked with a client for years and something suddenly feels off? Lauren Haines raised this from a conveyancer’s seat, not an AML technical one.
“I’ve seen a lot of conveyancers who’ve looked after clients for five, ten, or twenty years suddenly feel uncomfortable about what to ask, what not to ask, and what track to go down, especially when something isn’t obvious.” — Lauren Haines, Principal Licensee and Director, The Conveyancing Group
Richard Storey’s advice: go with your gut feel. Most conveyancers develop a pretty good instinct for their clients over time, since these are transactions that matter to people’s lives, and you get to know someone quickly. If you’ve known a client for a long time and something suddenly feels off, that instinct is usually worth listening to.
It’s a moral dilemma, Lauren agreed, but if you’ve had that suspicion, there’s probably a reason for it.
If I file a suspicious matter report (SMR), does that mean I have to stop the transaction? No, and Richard Storey was clear on this point. Filing an SMR doesn’t require you to pause anything or launch an investigation of your own. Your suspicion is enough to report; AUSTRAC and law enforcement take it from there. Once you’ve formed grounds for suspicion, you have three days to lodge the report.
How do I submit my annual compliance report? Log in to AUSTRAC Online, go to Business, then Compliance reports. Your first reporting period runs from 1 July 2026 to 30 June 2027, with the report due by 30 September 2027. AUSTRAC makes the questions available in advance, so it’s worth reviewing them ahead of time.
Missed the session?
Watch the full recording below.
Didn’t get your question answered, or need help setting up your triSearch Compliance Centre? Contact your account manager or raise a support ticket through triConvey or triSearch.
