AML/CTF · Legal Practice

Your Law Firm Is Now an AUSTRAC Reporting Entity — Here's What That Actually Means | AML/CTF Law Firms Australia 2026

Published 14 November 2025Last reviewed June 20266 min readBy Paul Wise

For most of its history, Australia's anti-money laundering regime was something that happened to banks. From 1 July 2026, that changed. Under the Tranche 2 reforms to the AML/CTF Act, a wide range of legal work was brought inside the regime — and many practices became AUSTRAC reporting entities without changing a thing about how they operate.

This is a plain-English explainer of what triggered the obligation, which legal services are caught, and the practical first steps. It is general information for legal practices, not legal advice — your exact position depends on what your firm does.

What actually triggered the obligation

The regime does not regulate "lawyers" as a profession. It regulates specific activities the law calls designated services. Your firm is a reporting entity for AML/CTF purposes when it provides one or more of those services in the course of carrying on a business, with a connection to Australia. Provide none of them and you may have no obligations at all; provide even one and you are a reporting entity for that work.

AUSTRAC takes a broad view of "carrying on a business." A service can be caught even if it is provided infrequently, as a one-off, or without a separate fee — so low volume does not put you out of scope.

Which legal services are designated

The activities most likely to bring a legal practice into the AML/CTF regime include:

  • Conveyancing — assisting a client to buy, sell or transfer real estate: preparing or reviewing the contract of sale and transfer documents, researching title, coordinating with lenders, and holding and disbursing funds at settlement.
  • Handling client money or assets in connection with a transaction — receiving, holding, controlling or managing a client's funds, accounts, securities or other property when you're helping them plan or carry out a transaction.
  • Company and trust formation or restructuring — creating, restructuring or helping to sell companies, trusts or other legal arrangements.
  • Acting in certain roles — acting as (or arranging for someone to act as) a director, secretary, trustee, partner or nominee shareholder, or providing a registered office address.
One nuance worth understanding: simply operating a trust account is not, by itself, a designated service. What matters is whether the money or assets are being handled in connection with a designated transaction. Settlement funds held only to support litigation advocacy can fall outside the net — but move those same funds in connection with a property sale and the position changes.

Purely advisory work — giving legal advice, appearing in court, litigation — is not caught by the designated services as a standalone activity. The trigger is the transactional work: handling the funds, forming the structure, settling the property.

The three things to do first

If your firm provides one or more designated services, three foundational steps come first:

  • Enrol with AUSTRAC. Enrolment opened on 31 March 2026. You generally must enrol within 28 days of starting to provide a designated service — which, for most solicitors already doing this work, means enrolling by 29 July 2026. Enrolment places your practice on AUSTRAC's Reporting Entities Roll.
  • Appoint an AML/CTF Compliance Officer. This must be someone with enough seniority, authority and independence to oversee the program and have it taken seriously. In a small firm this is often a principal or partner, and the role carries real personal accountability.
  • Develop your AML/CTF Program. This is the written framework governing how you manage money-laundering and terrorism-financing risk — a risk assessment plus your policies. You develop and maintain this program and produce it to AUSTRAC on request; you do not lodge it with AUSTRAC.

It is worth being clear-eyed about the stakes without overstating them: civil penalties under the AML/CTF Act apply per contravention and can run into the millions for a body corporate, and each affected matter can be a separate contravention. On top of that sit reputational exposure and potential disciplinary action from your state law society. AUSTRAC has signalled a supportive posture early on — while making clear that not knowing the rules will not be a defence.

Where Veriqua fits

Ninety days is less time than it sounds once you account for mapping services, enrolling, building the program, choosing identity-verification tools and training staff. This is the gap Veriqua is built to close. Veriqua is an Australian compliance operating system for AUSTRAC-regulated reporting entities, with legal-sector obligations and workflow templates pre-loaded — not a blank-slate tool.

It helps you map which of your services are designated, stand up and maintain your ML/TF risk assessment and AML/CTF policies, run KYC and beneficial-ownership verification on your clients, manage CDD records, monitor matters for suspicious activity and lodge SMRs inside their statutory deadlines. Two minutes, no login: demo.veriqua.com.au/start.

Frequently Asked Questions

Is my law firm an AUSTRAC reporting entity from 1 July 2026?
It depends on what your firm does, not the fact that it is a law firm. If you provide one or more designated services under the AML/CTF Act — such as conveyancing, handling client money in connection with a transaction, forming companies or trusts, or acting as a director or nominee — you are a reporting entity for that work from 1 July 2026. Purely advisory or litigation work is generally not caught.
What is a designated service for Australian legal practices?
Designated services for legal practices include: assisting a client to buy, sell or transfer real estate (conveyancing); receiving, holding or managing client money or assets in connection with a transaction; creating or restructuring companies, trusts or other legal arrangements; and acting as, or arranging for someone to act as, a director, secretary, trustee, partner or nominee shareholder.
When must a law firm enrol with AUSTRAC under Tranche 2?
Enrolment opened on 31 March 2026. A firm that was already providing designated services at 1 July 2026 must generally enrol within 28 days — by 29 July 2026. A firm that starts providing designated services after that date must enrol within 28 days of starting. Failure to enrol is a contravention of section 51B of the AML/CTF Act.
Does operating a law firm trust account make me an AUSTRAC reporting entity?
Not by itself. Operating a trust account is not a designated service. What matters is whether the funds in the account are being handled in connection with a designated transaction — such as settlement funds for a property conveyance. Funds held solely in connection with litigation advocacy, for example, may fall outside the regime.

See how Veriqua handles this

Veriqua is an Australian compliance operating system for AFSL holders and AUSTRAC reporting entities — automating AML/CTF programs, customer due diligence, transaction monitoring, SMR lodgement and board reporting.

Disclaimer: This article is general information only and is current as at November 2025. It reflects our understanding of the AML/CTF reforms, the AML/CTF Amendment Act 2024 and AUSTRAC guidance as at that date, all of which may change. It is not legal, financial or compliance advice and must not be relied on as such. Whether your firm provides a designated service depends on your specific circumstances. Please confirm your position against current AUSTRAC guidance and the AML/CTF Act and Rules, and with your professional body and advisers, before acting.