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Anti-Money Laundering (AML) – Counter-Terrorism Financing (CTF) Reform

Background and Resources
From 1 July 2026, the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Amendment Act 2024 (Cth) is in effect, extending Australia’s AML/CTF regime to legal practitioners for the first time. Lawyers providing certain legal services – known as “designated services” – are now required to verify client identity, report suspicious matters, and maintain AML/CTF programs and risk assessments. Clients may be asked to provide additional information and identification documents before a lawyer can act for them.

Why are the changes happening? Legal practitioners can sometimes – wittingly or unwittingly – be used to facilitate money laundering. The reforms bring Australia in line with international standards set by the Financial Action Task Force (FATF), and aim to strengthen Australia’s AML/CTF regime and protect the community from serious and organised crime.

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AUSTRAC Updates

Information for Lawyers (Please keep an eye on the Law Society of Tasmania’s Law Letter Hub and Weekly Update newsletters for information about AML/CTF)

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Resources

Articles

Complying with your AML/CTF obligations
From 1 July 2026, AML/CTF obligations are in force for legal practitioners providing designated services. The Law Society, through its national body the Law Council of Australia, continues to work with AUSTRAC on guidance notes and rules to assist with day-to-day operation of the AML/CTF Act.

  1. Review your practice: Carefully assess the services you provide against the list of designated services – this is the most critical step in determining your obligations. If you conclude your firm does not provide designated services, document your assessment with an explanation as to why, and date the record. Communicate this to all staff to ensure no one inadvertently provides a designated service, and review your position at least annually or if your practice changes. If you do provide designated services, you will be required to enrol with AUSTRAC.
  2. Enrol with AUSTRAC: Mandatory for those providing designated services. The deadline to enrol without penalty is 29 July 2026. If your firm begins providing a designated service after that date, you must enrol within 28 days.
  3. Develop and maintain an AML/CTF program: Your program must be based on a risk-based approach, including an assessment of the money laundering and terrorism financing risks within your practice.
  4. Appoint a compliance officer to own and oversee your AML/CTF program.
  5. Conduct customer due diligence (CDD): Verify the identity of clients and beneficial owners before providing designated services. Familiarise yourself with Know Your Customer (KYC) obligations and conduct ongoing CDD monitoring for any changes that may impact a client’s risk profile or indicate unusual or suspicious behaviour.
  6. Report certain transactions and suspicious activity: Lodge Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs) as required.
  7. Make and keep records for at least 7 years.
  8. Undertake training and education: Explore available resources and training programs – see the Resources section above.
  9. Stay informed: The Law Society of Tasmania continues to provide updates as guidance develops.

Key Dates

  • 29 July 2026 – Deadline to enrol: To avoid penalties.
  • Within 28 days of starting to provide a designated service: If a firm begins providing a designated service after 29 July 2026, it must enrol within 28 days.
  • 31 March annually (commencing 2027): The annual AML/CTF compliance report is due for the preceding calendar year (i.e. 1 January – 31 December).
  • From 1 July 2026 onwards – Reporting obligations: Law firms must lodge Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs, for cash ≥ AUD 10,000) as reportable matters arise.
    Timing of reporting:
    An SMR must be submitted:
    • within 24 hours where the suspicion relates to terrorism financing;
    • within 5 business days where the SMR includes information protected by legal professional privilege; or
    • within 3 business days in any other case.

Designated Services
If a legal service is what is known in the AML-CTF Act as a designated service, the new anti-money laundering obligations will apply. These include services assisting clients to:

  • buy, sell or transfer real estate;
  • buy, sell or transfer legal entities;
  • receive, hold, control or manage funds and/or property, for example money, accounts, securities or assets;
  • sell or transfer a shelf company;
  • carry out some transactional work, including equity and debt financing; and
  • create or restructure a legal entity or legal arrangement.

The new AML-CTF Act also captures services where the legal practitioner:

  • acts (or arranges for another person to act) as a director, partner, trustee, or pursuant to a power of attorney etc.;
  • acts (or arranges for another person to act) as a nominee shareholder; and
  • provides a registered office address or principal place of business.