Can a conveyancer refuse to settle if CDD is incomplete?

People search “conveyancer refuse settle incomplete CDD” when a conveyancer is at settlement with a party whose identity check is still unfinished. Checked against AUSTRAC’s initial customer due diligence overview on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. How a permitted delay works is on delayed initial CDD. The conveyancer’s service itself is on AML for conveyancers assisting a transfer. The sector map is /tranche-2.

The AML answer on settlement morning

Initial customer due diligence is timed to the designated service. For many conveyancers that service is assisting the transfer. If the check is unfinished when you would provide it, you wait. Calling that a refusal to settle describes the calendar.

It does not add a new power, and it does not come from an unpaid invoice. A delay, where the program allows one, is the only bridge. It is not a standing practice of settling first and identifying later. If the program has no such delay for this file, the settlement does not cure the gap; tell the client early enough that the link can still be completed; this page does not say what the other side can claim under the contract.

• Look at the program line, not the PEXA time. The workspace clock is not the AML clock. The program says when the service is provided.
• Name the missing piece. Person not started, company half done, or beneficial owner still unknown. “Not comfortable” is not a status.
• Do not trade the gap for a file note. A sentence that says the client promised to bring identity after settlement is not customer due diligence.
• Separate money from identity. Chasing your professional fee is a different conversation from stopping a designated service.

Four file states before you book the time

The morning of settlement is a bad time to discover the state. A conveyancer can sort the file the day before into one of four rows and act on that row only.

Where the refusal page stops

This page is the AML gate at settlement. It is not the delay article and it is not the guide to assisting a transfer. Those are delayed initial CDD and AML for conveyancers assisting a transfer. FreeAML does not refuse settlement and does not read the contract.

The firm suite is A$0. The check that would let the service proceed is client-pays.

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. The firm suite does not include a decision to refuse settlement, and it does not include advice on the contract. Confirm the live amounts on FreeAML pricing. FreeAML does not tell you to refuse settlement or interpret the sale contract.

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