---
title: "Legal Sector AML/CTF Compliance | HeadStart Docs"
description: "Lawyers AML/CTF under Tranche 2: trust accounts, client ID, conveyancing (QLD/ACT). Obligations start 1 July 2026. Free sector report available."
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Legal Sector

# Law practices with trust accounts or Table 6 designated services are reporting entities. Here's what you need to know before 1 July 2026.

From 1 July 2026, new AML/CTF compliance obligations reforms (called Tranche 2) will apply to the Legal Sector. AUSTRAC enrolment opens 31 March 2026.

![Law practices with trust accounts or Table 6 designated services are reporting entities. Here's what you need to know before 1 July 2026. professionals](/assets/law-practice-office-DG6e00li.jpg)

## The path to 1 July 2026 is defined by clear legislative and regulatory milestones

AML/CTF Amendment Act Passed

Nov 2024

Finalisation of AML/CTF Rules

Aug 2025

Finalisation of Core Guidance from AUSTRAC

Oct 2025

Finalisation of Sector-Specific Guidance for Lawyers

Jan 2026

AUSTRAC Enrolment Opens for Law Firms

31 Mar 2026

Mandatory Compliance Commences

1 Jul 2026

Note the critical six-month window between receiving final, lawyer-specific guidance and the mandatory start date. Preparation cannot wait.

## These reforms are driven by

### FATF Standards

The primary driver is the Financial Action Task Force (FATF), the global standard-setter for combating financial crime. Australia is a founding member and subject to its peer reviews.

### 2015 Evaluation Gap

Australia's 2015 FATF evaluation highlighted a key deficiency: the lack of regulation for "gatekeeper" professions like lawyers, accountants and real estate agents.

### Criminal Exploitation

Criminals exploit these professional services to conceal illicit funds, hide beneficial ownership through complex structures and add a veneer of legality to the proceeds of crime.

### Tranche 2 Reforms

The Tranche 2 reforms close this long-standing vulnerability, strengthening the integrity of Australia's financial system.

## ML/TF/PF Risks in the Legal Sector

The legal sector faces many unique money laundering (ML), terrorism financing (TF) and proliferation financing (PF) risks. If an entity offers designated services, they will need to be aware of and assess the risks in relation to their business and services offered.

#### Cuckoo Smurfing

Wire transfer manipulation

Criminals exploit trust accounts by structuring payments through multiple client matters to obscure the origin of illicit funds.

#### Testamentary Trust Abuse

Estate planning exploitation

Complex trust structures used to layer proceeds of crime through legitimate estate planning arrangements.

#### DPRK Identity Fraud

Sanctions evasion

Sanctioned entities using sophisticated identity fraud to engage Australian law firms for legitimate-appearing transactions.

#### Shell Company Formations

Corporate veil exploitation

Requests to establish corporate structures designed to obscure beneficial ownership and facilitate money laundering.

#### Cash-Intensive Transactions

Physical currency risks

Large cash deposits into trust accounts for property settlements or litigation funding without clear source.

#### PEP Exposure

Political figure involvement

Politically exposed persons using law firms to acquire property or establish trusts to conceal wealth.

### Industry References

[NRA: Money Laundering (2024) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/money-laundering-australia-national-risk-assessment-2024)• [NRA: Terrorism Financing (2024) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/terrorism-financing-australia-national-risk-assessment-2024)• [NRA: Proliferation Financing (2022) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/proliferation-financing-australia-national-risk-assessment-2022)• [LCA: AML/CTF Guidance (2024) ](https://lawcouncil.au/resources/policies-and-guidelines/national-legal-profession-anti-money-laundering---counter-terrorism-financing-guidance)• [FATF NRA Guidance (2025) ](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Money-Laundering-National-Risk-Assessment-Guidance.html) 

Designated Services 

## Your obligations are triggered only if you provide a 'designated service' in the course of your business

### Reporting Entity Status

Your firm becomes a 'reporting entity' under the AML/CTF Act when it provides one or more services listed in the legislation.

### Gatekeeper Focus

The focus is on transactional and structuring services where lawyers act as 'gatekeepers,' not on all legal work.

### Service Mapping

The first critical step for every firm is to conduct a detailed mapping of its service offerings against the statutory definitions to determine its regulatory status.

## Many core corporate, commercial and private client services are now in scope

Real Estate Transactions 

Assisting in the sale, purchase, or transfer of real property.

General Practice, Conveyancing, Real Estate & Property Law.

Entity & Business Transactions 

Assisting in planning or executing the sale, purchase, or transfer of a body corporate or legal arrangement.

General Practice, M&A, Corporate Law, Private Equity, Commercial Law.

Client Asset Management 

Receiving, holding, controlling, or managing a person's money, accounts, securities, or virtual assets for a transaction.

General Practice, Estate Planning & Administration, Restructuring, Commercial Law.

Financing Transactions 

Assisting in organising, planning, or executing equity or debt financing for a corporate or legal arrangement.

General Practice, Commercial Law, Corporate Law.

Entity Creation & Structuring 

Assisting in the creation or restructuring of a company or legal arrangement (e.g., an express trust).

General Practice, Corporate Law, Equity Law, Wills & Estates.

Restructuring 

Assisting in the reorganisation, restructuring, or winding up of a company or legal arrangement.

General Practice, Insolvency Law, Corporate Law.

Trust & Company Services 

Acting as (or arranging for another to act as) a director, secretary, trustee, nominee shareholder, or registered office.

General Practice, Corporate Law, Equity Law.

Service Category

Triggering Activity

Common Practice Areas Affected

Real Estate Transactions 

Assisting in the sale, purchase, or transfer of real property.

General Practice, Conveyancing, Real Estate & Property Law.

Entity & Business Transactions 

Assisting in planning or executing the sale, purchase, or transfer of a body corporate or legal arrangement.

General Practice, M&A, Corporate Law, Private Equity, Commercial Law.

Client Asset Management 

Receiving, holding, controlling, or managing a person's money, accounts, securities, or virtual assets for a transaction.

General Practice, Estate Planning & Administration, Restructuring, Commercial Law.

Financing Transactions 

Assisting in organising, planning, or executing equity or debt financing for a corporate or legal arrangement.

General Practice, Commercial Law, Corporate Law.

Entity Creation & Structuring 

Assisting in the creation or restructuring of a company or legal arrangement (e.g., an express trust).

General Practice, Corporate Law, Equity Law, Wills & Estates.

Restructuring 

Assisting in the reorganisation, restructuring, or winding up of a company or legal arrangement.

General Practice, Insolvency Law, Corporate Law.

Trust & Company Services 

Acting as (or arranging for another to act as) a director, secretary, trustee, nominee shareholder, or registered office.

General Practice, Corporate Law, Equity Law.

## Who May Be Captured?

The key trigger is designated services. If you are unsure whether you are covered, please take legal advice. Even if you are not covered, you may consider implementing guardrails.

Sole practitioners

Independent lawyers providing designated services

Independent practices

Small to medium law practices

Law firm partnerships

Traditional partnership structures

Multi-disciplinary practices

Firms offering legal and other professional services

Conveyancers

Real estate transactions are a key designated service

Outsourced legal service providers

In some cases

Whether you are captured depends on the designated services you provide. If unsure whether you're covered, please seek legal advice. Even if you are not covered, you may consider implementing guardrails to ensure you don't accidentally cross lines.

## The reforms target gatekeeper roles, not the practice of law itself

The following activities are generally not designated services, provided they are not part of a broader in-scope service:

### Litigation and Dispute Resolution

Including advocacy, running litigation and managing settlement payments under court order.

### Pure Legal Advice

Providing legal opinions or advice on law and regulation that does not involve planning or executing a specific transaction listed in Table 6.

### Employment Law

Work such as drafting employment contracts, enterprise agreements and unfair dismissal claims.

### Standalone Document Drafting

Preparing contracts like supply agreements or NDAs where the firm is not involved in the underlying transaction or managing client assets.

### Acting as Counsel/Barrister

Pure advocacy and advisory functions when instructed by a solicitor.

### Simple Wills & Estate Administration

Drafting simple wills, following court orders and post-death estate administration are generally not designated services. However, complex pre-death estate planning involving the creation of trusts or companies for a living client is a designated service.

## Once you are a reporting entity, you have six fundamental compliance  obligations

### 1.  Enrol with AUSTRAC

Formally register your practice as a reporting entity.

### 2.  Develop & Maintain an AML/CTF Program

Create a written, risk-based program tailored to your firm's specific ML/TF risks. This is the cornerstone of your compliance.

### 3.  Conduct Customer Due Diligence (CDD)

Identify and verify your clients and their beneficial owners before providing a designated service, and monitor them on an ongoing basis.

### 4.  Report to AUSTRAC

Submit Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs) as required.

### 5.  Keep Records

Maintain all relevant records of CDD, transactions and your AML/CTF program for prescribed periods.

### 6.  Appoint an AML/CTF Compliance Officer

Designate a senior individual responsible for the oversight of your program.

## Legal Professional Privilege is protected by law, but managing it under SMR deadlines is a new, high-stakes operational challenge

### The Statutory Protection

The AML/CTF Act (s 242) explicitly preserves your right to claim LPP. You are not required to disclose privileged communications to AUSTRAC.

Where you claim privilege in response to a notice, you must submit a specific LPP Form to AUSTRAC in lieu of the privileged information.

### The Reporting Minefield

The obligation to report a Suspicious Matter (SMR) is not removed by LPP. You must report the suspicion based on non-privileged information.

Crucially, there are strict deadlines for submitting the LPP Form if privilege is the reason for withholding details in an SMR.

Suspected Terrorism Financing:  LPP Form due within 24 HOURS  of forming suspicion.

Other Suspicious Matters (e.g., Money Laundering):  LPP Form due within 5 BUSINESS DAYS  of forming suspicion.

#### Compliance Risk

Failure to have a rapid internal triage process for LPP claims could lead to a serious compliance breach. An "LPP Emergency Response Protocol" is essential.

## Key AML/CTF Areas for Legal Professionals

Under Tranche 2, legal professionals face new obligations when providing designated services. Our documentation helps you navigate these requirements with confidence, covering all critical compliance areas specific to legal service delivery, including conveyancing for QLD and ACT practices.

### Establishing Trusts and Power of Attorney

Documentation and verification procedures for trust establishment and power of attorney arrangements.

### Trust Account Management

AML/CTF controls for trust accounts, including monitoring, transaction verification and suspicious activity detection.

### Client Identity Verification

Initial and ongoing customer due diligence (CDD), including electronic verification methods and document requirements.

### High-Value Transaction Protocols

Enhanced due diligence triggers and procedures for high-value matters and complex transactions.

### Beneficial Ownership Records

Requirements for identifying and verifying beneficial owners of entities involved in transactions.

### Suspicious Matter Reporting

Workflows for identifying, escalating and reporting suspicious matters to AUSTRAC, including indicators and thresholds.

### Compliance Officer Duties

Appointment requirements, role description and ongoing responsibilities for AML/CTF compliance.

## Building an AML Program

Building an AML/CTF program for a legal practice requires multiple steps.

-   AML/CTF program framework for law practices 
-   Risk assessment worksheet (ML/TF/PF risks) 
-   Client identification and verification procedures 
-   Trust account AML controls and monitoring 
-   Conveyancing compliance workflows (QLD/ACT) 
-   Suspicious matter reporting procedures 
-   Staff Training Register for tracking completion 
-   Compliance officer role description 

![Legal professionals reviewing compliance documentation](/assets/legal-consultation-SdDZg_6z.jpg)

## Ready to Get Started?

We can help you get a headstart on your AML/CTF program. Sector-specific program documents, no subscription. Portal included (subject to licence terms).

### A HeadStart on Compliance

Sector-specific compliance documents to help you build your AML/CTF program.

### Ready-to-Customise Resources

Lawyer-ready to review for your business.

### Training & Record-Keeping

Staff Training Register, Compliance Officer appointment documents and portal-based training record-keeping.

[Get Started - Legal Sector Edition](/programs/legal-aml-program)

From $249 inc GST · or bring your own program

HeadStart Docs™ products are developed with reference to publicly available regulatory guidance. This is general information only and does not constitute legal advice. You should seek advice specific to your circumstances before making compliance decisions.

## Understanding the AML/CTF Reforms

AUSTRAC has published guidance on how the AML/CTF laws are changing for newly captured sectors, including legal practitioners.

Source: AUSTRAC, How Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws are changing (August 2025)

### State law society AML/CTF hubs

Every Australian law society has published dedicated AML/CTF resources. Find your state's hub below.

[QLS Queensland Law Society ](https://www.qls.com.au/resource-centre/anti-money-laundering-counter-terrorism-financing)[NSW Law Society of NSW ](https://www.lawsociety.com.au/practising-law-NSW/AML-and-CTF-Hub)[VIC Law Institute of Victoria ](https://www.liv.asn.au/amlhub)[SA Law Society of SA ](https://www.lawsocietysa.asn.au/site/site/for-legal-practitioners/resource-hubs/anti-money-laundering-and-counter-terrorism-financing.aspx)[WA Law Society of WA ](https://lawsocietywa.asn.au/resource-centre/practising-resources/aml-ctf-hub/)[TAS Law Society of Tasmania ](https://www.lst.org.au/anti-money-laundering-counter-terrorism-financing/)[ACT Law Society of the ACT ](https://www.actlawsociety.asn.au/practising-law/aml-ctf-1)[NT Law Society of the NT ](https://lawsocietynt.asn.au/index.php/2024/07/29/anti-money-laundering-counter-terrorism-financing/)[LCA Law Council of Australia ](https://www.lawcouncil.asn.au/policy-agenda/regulation-of-the-profession-and-ethics/anti-money-laundering)

[Designated services: not just for property lawyers](/tranche-2-resources/designated-services-not-just-property)

## Free Resources

[

### Legal Sector Industry Report

Free Tranche 2 Legal Sector Report. What the industry needs to know.



](/reports/legal-professionals)[

### AUSTRAC Starter Kits

When will they be out and what to expect.



](/tranche-2-resources/austrac-starter-kit-lawyers)[

### Tranche 2 Guide

Guide to the AML/CTF Amendments and Tranche 2.



](/tranche-2)

### Related Podcast Episode

Tranche 2 for Lawyers • 14:05

Share: [](https://www.linkedin.com/sharing/share-offsite/?url=https%3A%2F%2Fopen.spotify.com%2Fepisode%2F19OvazAE9cX4CL7Sr9vqK4)[](https://twitter.com/intent/tweet?text=Tranche%202%20for%20Lawyers&url=https%3A%2F%2Fopen.spotify.com%2Fepisode%2F19OvazAE9cX4CL7Sr9vqK4)[](<mailto:?subject=Tranche%202%20for%20Lawyers&body=Check out this podcast episode: https://open.spotify.com/episode/19OvazAE9cX4CL7Sr9vqK4>)

### Episode Notes

[From $249 ](/programs/legal-aml-program)

### AML/CTF Compliance by Practice Area

[Family Lawyers](/law-practice/family-lawyers)[Estate Lawyers](/law-practice/estate-lawyers)[Commercial Lawyers](/law-practice/commercial-lawyers)[Litigators](/law-practice/litigators)[Personal Injury Lawyers](/law-practice/personal-injury-lawyers)[Criminal Lawyers](/law-practice/criminal-lawyers)[Immigration Lawyers](/law-practice/immigration-lawyers)[In-House Counsel](/law-practice/in-house-counsel)[Employment Lawyers](/law-practice/employment-lawyers)

Related Sectors: [Conveyancing](/conveyancing)[Insolvency Practitioners](/insolvency-practitioners)[Accounting](/accounting)[TCSP](/tcsp)

### Learn More About Legal Compliance

[

Law Practice 

Law Practices and Tranche 2



](/tranche-2-resources/law-practices-tranche-2)[

Getting Started 

AUSTRAC Starter Kit for Lawyers



](/tranche-2-resources/austrac-starter-kit-lawyers)[

Implementation 

Working with Your Solicitor on AML/CTF



](/tranche-2-resources/working-with-solicitor)[

Law Practice 

Lawyers and Crypto Custody



](/tranche-2-resources/lawyers-crypto-custody)[

Reporting 

Tipping Off and Safe Harbour



](/tranche-2-resources/tipping-off-safe-harbor)[

Due Diligence 

Third-Party Reliance for KYC



](/tranche-2-resources/third-party-reliance-kyc)

### Free Tools for Lawyers

[Implementation Timeline Key dates and milestones for Tranche 2 compliance ](/timeline)[Readiness Test Assess your compliance readiness in 2 minutes ](/risk-calculator)[Sanctions Screening Search Australian sanctions lists and country risk ](/sanctions-search)

### Related Resources

[Legal Professionals Report](/reports/legal-professionals)

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### Sectors

[Accounting](/accounting)[Business Brokers](/business-brokers)[Buyers Agent](/programs/buyers-agent-aml-program)[Conveyancing](/conveyancing)[Insolvency](/insolvency-practitioners)[Legal](/law-practice)[Nominee Director](/programs/nominee-director-aml-program)[Precious Metals, Stones & Products](/precious-metals)[Property Development](/property-developers)[Real Estate](/real-estate)[TCSPs](/tcsp)[Virtual Address](/virtual-address)

### Resources

[Free Resources](/tranche-2-resources)[Decision Trees](/decision-trees)[Tranche 2 Guide](/tranche-2)[Podcast](/podcast)[Free Sector Reports](/sector-reports)[Implementation Timeline](/timeline)[Sanctions Search](/sanctions-search)[AUSTRAC Starter Kits](/tranche-2-resources/austrac-starter-program-kits)[Budgeting for Compliance](/tranche-2-resources/budgeting-amlctf-compliance)

### Programs

[Portal + AML Programs](/programs)[Pricing](/pricing)[White Label](/white-label)[External CRMs](/integrations)[AML Portal](/aml-landing)[Plug & Play Technology](/plug-and-play)[Lawyer in the Loop](/features/lawyer-in-the-loop)

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HeadStart Docs™ is a digital publisher and platform provider. We sell digital compliance products including publications and portal access to our AML Portal; we do not provide legal advice or services. The content on this website and in our products is for general information purposes only, does not consider your individual and business circumstances, and should not be relied on as legal advice. Referrals for legal advice can be made, on request, to HeadStart Counsel, the registered trading name of Astris Law Pty Ltd, a related incorporated legal practice with the same director and beneficial owner as HeadStart Docs. You are free to engage any legal practitioner of your choice.