Is property work covered?
AUSTRAC says lawyers and conveyancers who help plan or execute a property sale, purchase or transfer may be regulated under different designated services from agents.
Its example is a conveyancer who helps a parent transfer the family home to a child without payment. That will be a designated service.
Facts and sources for this part
- AUSTRAC: lawyers and conveyancers who help plan or execute the sale, purchase or transfer of real estate "may be regulated under different designated services" from agents. [S8]
- AUSTRAC: a conveyancer who helps a parent transfer the family home to a child without payment "will provide a designated service". [S8]
What does AUSTRAC list as legal-sector red flags?
- A client who tries to avoid know-your-customer steps.
- A client with an unusual level of knowledge about AML/CTF requirements.
- A client who appears to be following instructions from third parties.
Facts and sources for this part
- AUSTRAC legal-sector red flags: a client who "tries to avoid know your customer (KYC) processes" or "has an unusual level of knowledge about AML/CTF requirements". [S39]
- AUSTRAC accountant red flags: a client who "doesn’t seem to understand the business sector they’re operating in", "ends the relationship after you ask for more information" or "appears to be following instructions of third parties". [S38]
Who needs which track?
- Principals: senior manager track.
- The compliance officer: compliance officer track.
- Solicitors, conveyancers and paralegals who take instructions: front-line track.
- Reception and accounts staff: all-staff track.
Facts and sources for this part
Which lessons fit?
Every track begins with the duty. Add the suspicious matter lesson, because tipping off matters in a firm where several people see the file.