Contractor conveyancer engaged per file: personnel due diligence?

People search “contractor personnel due diligence AML” when a conveyancing practice engages a locum per settlement and assumes contractors sit outside personnel due diligence. Checked against AUSTRAC's page on personnel roles on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Training people who are not specialists is AML training for non-specialist staff. The sector map is /tranche-2.

The role, not the invoice

Contractor personnel due diligence AML is the question when a practice pays a conveyancer per file and hopes the word contractor ends the issue. AUSTRAC's personnel page is about roles that need due diligence and training. A locum who opens the matter, collects the customer's link, and tells staff the result is doing that work. The tax treatment of the invoice is a different system.

This page does not reproduce the list of roles. The firm reads the guidance, writes the roles into the program, and applies them to the contractor and to permanent staff the same way. A shorter engagement is not a quieter obligation.

• Describe the work. Running CDD on a settlement is a role. Delivering a plan to the front desk may not be. Write the difference.
• Ignore the payroll flag. Contractor, locum, and employee can perform the same role. The role is the test.
• Do not use the calendar as an exit. A week of settlements is still the role. 'Only a week' is not a category in the program.
• Keep client checks separate. Personnel due diligence is about your people. The client's KYC or KYB is a different check, and the client pays it.

Who is in the personnel question

Where the contractor page stops

This page is the per-file contractor. It is not the compliance officer appointment. That role sits on the compliance officer role. This page does not say every contractor in a practice is personnel, and it does not hand you a screening pack.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. Personnel due diligence on a contractor is not included in the firm suite, and it is not a client KYC check. Confirm the live amounts on FreeAML pricing. FreeAML does not decide which contractors are personnel, or screen your locum for you.

Frequently Asked Questions