Step 1: Customise your conveyancing program using the starter kit
Learn how to customise the conveyancing starter kit to your practice to help you meet your anti-money laundering and counter-terrorism financing (AML/CTF) obligations.
On this page
- Use the Customise the program starter kit guide
- What documents you need to customise
- Steps to customise the documents
- Next step
The starter kit isn't designed to be used as-is. You must complete this customisation step before using it. This will create an AML/CTF program that reflects your practice.
To customise your program using the starter kit, complete these steps by 1 July 2026.
Use the Customise the program starter kit guide
The Customise the program starter kit guide (Word, 1.05 MB) walks you through a 4-step process to customise the documents and forms that make up your AML/CTF program.
What documents you need to customise
Follow the Customise the program starter kit guide to customise these documents:
- Risk assessment(s)
- Policy document
- Process document.
You'll customise these documents so they reflect your practice model, services, clients and risks. After customising and approving these documents, they become your AML/CTF program.
Risk assessment(s)
This document contains:
- your risk assessment
- risk factors
- the controls you use to mitigate your risks
- risk indicators and methodologies.
You’ll refer to this document when reviewing risks, controls and major changes to your practice.
Based on feedback provided by your professional peak bodies, we've given you 2 risk assessments. You'll download and customise one or both of these risk assessments if you provide certain regulated services.
Download the conveyancing risk assessment (Word, 900 KB) if your practice provides conveyancing services.
Download the other professional services risk assessment (Word, 905 KB) if your practice provides other professional services, such as assisting in transactions to buy or sell a body corporate or legal arrangement (such as a trust).
Policy document
This document sets out:
- what your practice must do and when to meet its AML/CTF obligations
- who is responsible for key AML/CTF activities.
Download the policy document (Word 999 KB).
Process document
This document contains processes that describe:
- how you carry out AML/CTF activities in practice
- the minimum steps your practice must follow
- where you may use automated systems or tools instead of manual processes.
If you choose to use automated systems (for example, electronic verification or sanctions screening), those systems must meet or exceed these processes.
Download the process document (Word 999 KB).
Steps to customise the documents
Follow the 4-steps in the Customise the program starter kit guide to:
1. Customise your risk assessment(s)
You’ll identify which risks are relevant to your practice, how significant they are, and which risks you’re willing to accept. These decisions form the foundation for your risk controls.
2. Customise the personnel sections of the policy and process documents
Follow the guide to:
- assign AML/CTF roles to staff
- ensure staff are suitable for those roles by conducting personnel due diligence
- plan training.
This ensures your program reflects how your practice is structured and staffed.
3. Tailor the client sections of the policy and process documents
Follow the guide to establish how you:
- engage a new client – We use the term ‘onboarding’ in the starter kit documents
- apply customer due diligence (CDD) to understand who your clients are before you provide them a service
- monitor client activity
- respond to client risk.
4. Document and approve your program
Follow the customise guide to finalise your documents and have the program approved by your senior manager. For a typical conveyancing practice, this could be the practice owner or a senior conveyancer.
The guide includes steps to incorporate the forms into your existing systems and processes to implement your program.
Next step
Once customised and approved, your next step is to implement your AML/CTF program across your practice.
From 1 July 2026, your AML/CTF program will guide how you:
- deal with clients
- manage personnel
- meet your ongoing obligations.
Go to Step 2: Use your program.
The program starter kits are intended to be used as a complete package and have been designed for use by those reporting entities who satisfy certain suitability criteria. That suitability criteria is set out in the ‘Getting Started’ web page under the heading “Who the starter kit is for” in each program starter kit. In particular, those Tranche 2 entities who, from 1 July 2026, are for the first time subject to anti-money laundering and counter-terrorism financing legislation (AML/CTF).
The program starter kits have been designed for the purpose of providing practical guidance to those reporting entities to assist them to build their own AML/CTF programs. The program starter kits represent AUSTRAC’s interpretation and application of the law to the eligible reporting entities only and are not intended to represent an interpretation and application of the law in all circumstances. The program starter kits are not a substitute for legal advice about any reporting entity’s AML/CTF compliance obligations. Australian courts are ultimately responsible for interpreting the AML/CTF legislation and determining if any provision of these laws are contravened.
This guidance sets out how we interpret the Act, along with associated Rules and regulations. Australian courts are ultimately responsible for interpreting these laws and determining if any provisions of these laws are contravened.
The examples and scenarios in this guidance are meant to help explain our interpretation of these laws. They’re not exhaustive or meant to cover every possible scenario.
This guidance provides general information and isn't a substitute for legal advice. This guidance avoids legal language wherever possible and it might include generalisations about the application of the law. Some provisions of the law referred to have exceptions or important qualifications. In most cases your particular circumstances must be taken into account when determining how the law applies to you.