Complying with your ongoing AML CTF obligations - 10 practical steps
The requirements to comply with the AML CTF regime can be broken down into 10 practical steps.
The first four steps should be undertaken by all legal practices, as they concern the preparatory work needed to determine whether your practice will be subject to the new AML CTF obligations.
The remaining steps are for practices captured by the new Act (e.g. those that provide designated services).
To with your planning, we have included suggested “by no later than” timings, working backward from the commencement date of 1 July 2026.
Once the first four steps are completed, you are encouraged to develop your own AML CTF plan for implementation, tailored to your specific timeframes and resourcing constraints.
Step no. | What is required? | Suggested timing |
|---|---|---|
Step 1 | Read and familiarise yourself with the obligations under the new Act. | July to August 2025 |
Step 2 | Keep informed (subscribe for relevant updates from AUSTRAC and use available resources and CPD courses as you progress through to planning your AML CTF compliance program).
| July to August 2025 |
Step 3 | Get to know your practice from an AML CTF risk perspective.
If you haven’t already, gather data so you know what services you provide, how you provide those services, to whom you provide those services, and the locations you operate in. | August to October 2025 |
Step 4 | Consider whether your practice is, or will be, providing a designated service. If so, proceed to the remaining steps. | September to December 2025 |
Step 5 | Conduct a preliminary AML CTF risk assessment of your practice. | January 2026 |
Step 6 | Develop a plan for a tailored AML CTF program, considering factors such as your governance structure and the resources required for compliance (e.g. personnel, technology etc). | February 2026 |
Step 7 | Design your AML CTF compliance program and document the supporting AML CTF policies and processes. Consider how existing processes (e.g. client onboarding, trust account management) can be leveraged or adapted to meet compliance requirements. | February 2026 |
Step 8 | Appoint an appropriate AML CTF officer. | March 2026 |
Step 9 | Plan and deliver staff training. | March to April 2026 |
Step 10 | Enrol with AUSTRAC. | 1 July 2026 (enrolment will be open from 31 March 2026)
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We have developed this 10-step approach based on AUSTRAC guidance, together with guidance on preparing for AML CTF changes by other law societies and professional bodies. This general information does not constitute legal advice and is provided to help you navigate the steps required to implement the new obligations under the Act, which we encourage you to read.
