AML/CTF: Compliance without the complexity

Register your interest in InfoTrack's upcoming AML/CTF Roadshow, coming in 2026

What the AML/CTF amendment Act 2024 means for legal and conveyancing firms

The Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Amendment Act 2024 became law on 10 December 2024 and significantly impacts the legal industry, real estate industry and individuals buying and selling property. The reforms aim to close regulatory gaps by extending AML/CTF obligations to previously unregulated sectors, including legal and conveyancing.

If your business is now required to comply with AML/CTF regulations, it’s essential to understand your obligations and begin preparations as soon as possible. While the new requirements don’t take effect until 1 July 2026, the short compliance timeline and the limited availability of AML/CTF specialists in Australia mean demand for expertise will rise as the deadline approaches.

Under this new regime, law firms or licensed conveyancing firms are classified as a PSP, meaning you must adhere to AML/CTF regulations, and the services you provide are recognised as ‘Designated Services’.

This means your firm is subject to AML/CTF compliance measures, broadly covering:

Conducting employment due diligence (EDD) obligations
Conducting customer due diligence (CDD) including verifying clients' identities
Reporting suspicious transactions to AUSTRAC
Keeping records of transactions and client interactions, and
Implementing a risk-based AML/CTF compliance program.

Get ready for Tranche 2: Essential AML/CTF training for lawyers and conveyancers

Recent updates: Revised AML/CTF rules from AUSTRAC’s initial consultation

AUSTRAC has released a revised draft of AML/CTF Rules, with key updates for lawyers, conveyancers, and real estate professionals. This second draft provides further guidance for Designated Non-Financial Businesses and Professions (DNFBPs), particularly in the context of property transactions.

The draft clarifies that client due diligence on purchasers may be delayed when required but must still be completed before settlement. Vendor checks remain unchanged and are required at the start of the designated service.

The rules also formalise reliance between real estate agents and conveyancers for Know Your Client (KYC) purposes and allow enhanced due diligence to be applied at any stage based on client risk. Verification of Identity (VOI) checks via InfoTrack’s DVS integration remain compliant.

Additional guidance on risk ratings and reporting is expected in future updates.

Learn more about InfoTrack's AML/CTF solutions

Finally, InfoTrack is committed to continuing to provide input and guidance into the AUSTRAC consultation phase of the regime and will advocate for legal technology that serves your firm’s best interests.

Checklist: Your firm’s journey to compliance

AML/CTF Compliance Program

Firms will need to develop or choose a service provider to implement an AML/CTF Compliance Program

AML/CTF project lead appointed
Internal risk assessments to identify vulnerabilities
Staff training on AML/CTF obligations
Policies and procedures for CDD, reporting, and record-keeping
Regular audits and updates to reflect new risks

Customer Due Diligence (CDD) & Know Your Client (KYC)

Lawyers and conveyancers will need to verify their clients’ identities before providing a Designated Service. This includes:

Identifying and verifying clients using reliable, independent documents (e.g., passports, driver's licenses).
Identifying beneficial owners (e.g., trusts, companies) to prevent the use of legal services for money laundering.
Assessing risk : Firms must classify clients based on risk levels (e.g., high-risk clients may require enhanced due diligence).
Ongoing monitoring: Regularly review client activities to detect suspicious transactions.

Suspicious Matter Reporting (SMR)

If a transaction or activity appears suspicious—such as unusual payments, complex property transfers, or clients avoiding verification—firms must report it to AUSTRAC.

Record-Keeping Requirements

Lawyers and conveyancers must maintain detailed records for at least seven years