Trust account receipt from overseas: IFTI or not?
An overseas amount landing in a conveyancer’s trust account is not, by itself, an international funds transfer instruction made by the firm. The bank or the remitter may be the reporter of the transfer; the conveyancer still has customer due diligence, and a suspicion is a different report.
Quick answer
Ask who gave the instruction to move the money across the border. A receipt in the trust account is not that instruction. Cash at the threshold is a threshold transaction question, not an IFTI. A source of funds that does not fit the file goes to the suspicious-matter procedure; this page does not decide a live file.
People search “overseas deposit conveyancer trust account AML” when a conveyancer on a settlement sees a payer overseas and the trust receipt does not match the buyer named on the contract. Checked against AUSTRAC’s international funds transfer reports page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Property firms and IFTI generally are on IFTI for property firms. Cash into a trust account is who files a trust-account threshold report. The sector map is /tranche-2.
A receipt is not an instruction
International funds transfer instructions are a named report. They are about an instruction to move value internationally, made in the course of a designated service that carries that duty. A suburban conveyancer who watches cleared funds appear on the trust statement has seen a receipt.
The instruction may have been given to a bank. Treating every foreign payer as the firm’s own IFTI is how the wrong form gets lodged, and how the real question, which is the customer and the source of funds, gets skipped.
- Name the reporter. If the firm did not give the transfer instruction, do not assume the IFTI is yours. Read the IFTI guidance before you lodge.
- Keep CDD anyway. The buyer or other customer on the designated service is still identified under the program, whatever the bank reports.
- Split the cash question. Physical currency at the threshold is the threshold transaction report. It is not an IFTI with a new name.
- Suspicion is its own path. A payer who does not match the contract is a reason to use the suspicious-matter procedure, not a reason to pick a form at random.
Four things a trust receipt might be
Sorting an overseas receipt on a conveyance. This table does not reproduce AUSTRAC’s IFTI guidance.
| What you see | Report people reach for | First question |
|---|---|---|
| Foreign payer, electronic receipt | IFTI | Did this firm give an international transfer instruction? |
| Physical currency into the trust account | Threshold transaction report | Whose reporting duty is it, and is the cash threshold met? |
| Payer is not the customer on the file | Suspicious-matter procedure | Has the program’s escalation been followed, without telling the client? |
| Australian account, known buyer | Ordinary trust records | Is customer due diligence already finished for this service? |
Where the receipt page stops
This page sorts a conveyancer’s trust receipt. It is not the general property-firm IFTI note, and it is not the cash threshold note. Those are IFTI for property firms and who files a trust-account threshold report.
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. Sorting a receipt into a report type is not a KYB check, and the firm suite does not include that judgement. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a trust receipt is an international funds transfer instruction, or file either report.
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Frequently Asked Questions
The receipt question is separate from the customer check.
The firm suite is A$0. The client pays the check the program requires. Email the client a link.
Open an AML checkQuestions: team@freeaml.com.au