Anti-Money Laundering and Counter-Terrorism Financing (AML CTF)
Major reforms to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and Australia’s broader AML CTF regime will take effect for Australian legal practitioners in July 2026.
AUSTRAC have announced that for those businesses who will come under regulation next July, AUSTRAC expects that by July 2026, you will:
- be enrolled as a reporting entity (if you deliver designated services). The online enrolment system opens 31 March 2026.
- have an AML program, either because you have adapted the starter program provided by AUSTRAC or have developed your own.
- have an AML CTF Compliance Officer (AMLCO)
- have trained your staff on your AML CTF program and processes
- be ready to ask clients questions and report suspicious activity.
To support you in navigating these changes and prepare for implementation, we have developed this AML CTF Hub – a dedicated platform to bring together key resources and information from the Law Society, AUSTRAC, the Law Council of Australia and other constituent legal professional bodies.
Latest updates
- AUSTRAC enrolment open now – Enrolment is now open for sectors and professions to be covered by new anti-money laundering and counter-terrorism financing (AML CTF) laws. Tranche 2 businesses, including legal practices, who meet the definition of providing a designated service are required by 1 July 2026 to be enrolled with AUSTRAC.
- Sanctions compliance guidance notes for legal professionals – The Australian Sanctions Office within the Department of Foreign Affairs and Trade has published this guidance note which covers information relevant for legal professionals managing sanctions risks in connection with providing legal services.
- Starter kits – AUSTRAC have released their starter pack to help small legal practices create their own AML CTF program. The starter kit should be assessed for suitability for your practice and then adapted to meet your practice’s specific needs. Check out Fiona Halsey’s recent Brief article which explains why they’re so useful. Neil Jeans also discusses how to assess their suitability and adapt them in his CPD AML CTF Update (available on demand for members through CPD Online).
- Transitional rules for AML CTF compliance – The AML transitional rules came into effect from 31 March. Under the rules, there will be a transitional period for initial customer due diligence for current reporting entities, a registration roll-over and a staggered rollout for the independent evaluations. A detailed summary is available.
- Updated OAIC guidance – privacy obligations under AML CTF – The Office of the Australian Information Commissioner (OAIC) has released updated Privacy guidance for reporting entities under the AML CTF Act which provides clear direction to businesses about what personal information they may collect, how they must protect it, and when it must be deleted, supporting stronger integrity and transparency across the AML CTF regulatory framework. The OAIC has developed a Privacy Essentials Checklist for AML/CTF reporting entities to prepare for key privacy obligations and encourages all reporting entities and their authorised agents to review the guidance along with the Australian Privacy Principles Guidelines, AUSTRAC’s guidance on AML CTF reforms- external site as well as AUSTRAC’s Program Starter Kits- external site.
- Updated suspicious matter reporting reference guide – Based on industry feedback, AUSTRAC have recently updated their Suspicious matter reporting reference guide
- AUSTRAC Industry Update – the latest update from AUSTRAC is now available here.
- 10 Practical Step Guide to AML CTF compliance – Our 10 step practical guide provides oversight into the steps lawyers should be taking to prepare for AML CTF commencing in July 2026
- AUSTRAC Industry Regulator Update – The latest regulator update is available here.
- Webinar Recordings – AUSTRAC’s second webinar “An overview of key AML CTF obligations” is available online. The webinar covers enrolment, developing a program, policies, customer due diligence (CDD), transaction monitoring, governance, reporting, independent evaluations and record keeping. To go deeper into specific topics, check out these other webinar recordings – ML TF risks, CDD, Outsourcing.
- Ongoing advocacy – We continue to actively contribute to ongoing consultations on the guidance and other supporting materials being developed by AUSTRAC. For more information about advocacy, see Submissions and Consultations. Please note that some of these consultations are confidential and our submissions cannot be shared on the website
- Updating members – Together with our AML CTF Working Group, we continue to engage with AUSTRAC through industry consultation sessions about the draft rules and guidance. We will keep members informed about AML CTF changes as they develop through this Hub, CPDs and Friday Facts.