AUSTRAC have released new guidance on the AML/CTF reforms. Until the laws take effect on 31 March 2026, the AUSTRAC website will continue to reflect current obligations.
For information on your responsibilities from 31 March 2026 onwards, please refer to AUSTRACs AML/CTF reforms guidance.
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. Registration for reporting entities opens on 31 March 2026, giving firms a crucial window to ensure readiness and avoid last-minute compliance pressure.
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:
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.
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.
AML/CTF Compliance Program
Firms will need to develop or choose a service provider to implement an AML/CTF Compliance Program
Lawyers and conveyancers will need to verify their clients’ identities before providing a Designated Service. This includes:
