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.
Join our webinar on
AML/CTF compliance for new entrants
Neil Jeans, Partner–Risk Consulting, Grant Thornton
- 30 April
- 12pm AEST
- 1 CPD
As this law is fast approaching a compliance deadline, your firm should now be in the planning phase and well on your way to developing an internal compliance program.
As your leading legal tech provider, we are working on readying the InfoTrack software solutions you use each day to be compliant ready for any additional employee checks and client onboarding checks you will need to conduct. Not every firm is the same, and so our Client Relationship Managers are ready to talk with you about your specific processes.
We are also committed to your firm’s ongoing education and training in relation to the regime and we will be releasing training for your firm in the coming months.
We are also thrilled to announce that we are working in partnership with Grant Thornton to provide you with services to support the development and implementation of your firm’s internal AML/CTF compliance framework.
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
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 transactions must be reported within three business days.
- If terrorism financing is suspected, it must be reported immediately.
- Identity verification documents
- Client due diligence assessments
- Transaction details
- Communications
- Reports submitted to AUSTRAC
