AML/CTF Compliance Roadmap

Understanding your obligations under Australia's expanding Anti-Money Laundering and Counter-Terrorism Financing regime.

From 1 July 2026, Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regulations will extend to the legal profession. This represents a significant new compliance obligation for many practices. To help you prepare, we have developed a compliance roadmap.

Use the flowchart below to conduct a preliminary assessment of your practice, determine if your services fall under the new regulatory regime, and understand the critical next steps for ensuring you are compliant by the deadline.

Preliminary Practice Assessment

As Australia extends AML/CTF regulations to the legal profession from July 2026, practitioners must evaluate whether their services fall within the new regulatory framework.

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Does your practice offer any designated services?

Review the following nine categories of legal services that will trigger AML/CTF reporting obligations:

Real Estate Transactions

Planning, execution, or acting in a transaction to buy, sell, or transfer real estate

Business and Corporate Transactions

Planning, execution, or acting in a transaction to buy, sell, or transfer a body corporate or legal arrangement

Management of Funds and Assets

Receiving, holding, and controlling/managing a person's money, accounts, securities, or virtual assets

Corporate Finance

Assisting in organising, planning, execution, or acting in a transaction for equity or debt financing relating to a body corporate or legal arrangement

Shelf Companies

Selling or transferring a shelf company

Corporate Structuring

Assisting in planning, execution, or acting in the creation or restructuring of a body corporate or a legal arrangement

Acting in Key Corporate Roles

Acting as or arranging another person to act as a director, secretary, Power of Attorney of a body corporate, a partner, or a trustee of an express trust

Nominee Shareholders

Acting as or arranging another person to act as a nominee shareholder

Registered Office Services

Providing a registered office address or principal place of business of a body corporate or legal arrangement

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Practice Excluded from AML/CTF

Implement Service Restrictions

Establish internal protocols and client engagement procedures to ensure your practice does not inadvertently provide regulated services

Monitor Service Scope

Continuously monitor the services provided by your practice to ensure that if any designated services are undertaken, proper AML/CTF compliance measures are implemented

Monitor Regulatory Updates

Regularly monitor AUSTRAC and Law Society updates to ensure the practice is not undertaking regulated services without adherence to the AML obligations

Practice Subject to AML/CTF Regime

Review Resources

Start by reviewing AUSTRAC's AML/CTF reform page and the Law Society SA's AML CPD webinar series to understand the regulatory framework and requirements

Designate Compliance Responsibility

Appoint an AML/CTF Compliance Officer - this may be a principal, senior practitioner, or dedicated staff member depending on your firm's size and structure

Begin Scaled Implementation Planning

Start planning compliance systems appropriate to your firm's size - focus on practical procedures that can be realistically implemented and maintained

Regulatory Implementation Schedule

Phase 1: Preparation (By March 2026)

Phase 2: Operation (By July 2026)

Note: The above links are subject to change as AUSTRAC is currently preparing to release sector-specific guidance for legal practitioners.

⚠️ Critical Compliance Deadline

You must enrol with AUSTRAC within 28 days of providing a designated service to avoid penalties. If you provide newly regulated designated services, the new laws commence on 1 July 2026, and you must enrol by 29 July 2026. Non-compliance may result in significant penalties and regulatory action.

💡 Risk Assessment Considerations

When conducting your firm-wide AML/CTF risk assessment, consider client types, transaction values, geographic locations, service delivery methods, and the complexity of legal structures involved in matters that your practice deals with.