--- title: "AML/CTF: Not Just for Property Lawyers — Designated Services for Legal Practices | HeadStart Docs" description: "AML/CTF designated services go far beyond conveyancing. Company transfers, trust creation, financing, nominee arrangements — see which law practices are captured and find your state law society's AML/CTF hub." lang: en-AU json-ld: | [ { "@context": "https://schema.org", "@type": "Organization", "name": "HeadStart Docs", "legalName": "HeadStart Docs Pty Ltd", "url": "https://www.headstartdocs.com.au", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png?v=4", "width": 512, "height": 512 }, "description": "AML/CTF compliance digital products and programs for Australian businesses under Tranche 2 regulations. Free program documents and AML Portal. 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HeadStart Docs products are digital publications that give you a substantial head start, but they must be reviewed and tailored by a qualified solicitor to your specific business circumstances before implementation." } }, { "@type": "Question", "name": "How is HeadStart Docs different from the free AUSTRAC Starter Kits?", "acceptedAnswer": { "@type": "Answer", "text": "AUSTRAC Starter Kits are generic starting points that require significant customisation. HeadStart products are sector-specific, pre-populated with industry-relevant risk factors and scenarios, and include 12 months of AML Portal access for ongoing compliance including screening, record keeping and reporting tools." } }, { "@type": "Question", "name": "What if the AML/CTF rules change after I purchase?", "acceptedAnswer": { "@type": "Answer", "text": "Your digital products are yours to keep. If significant regulatory changes occur, updated versions will be available to active portal subscribers. The AML Portal itself is continuously updated to reflect current AUSTRAC requirements and sanctions lists." } }, { "@type": "Question", "name": "What happens after my 12-month AML portal access expires?", "acceptedAnswer": { "@type": "Answer", "text": "Your documentation is yours forever. To continue using the AML Portal (screening tools, compliance calendar, record keeping), you pay $35 per customer CDD. Cancel anytime — no subscription required." } }, { "@type": "Question", "name": "Is HeadStart Docs a law firm?", "acceptedAnswer": { "@type": "Answer", "text": "No. HeadStart Docs is a digital publisher and platform provider. We sell digital compliance products and portal access. We do not provide legal advice. Referrals for legal advice can be made to our related law firm, HeadStart Counsel." } }, { "@type": "Question", "name": "When does AML/CTF Tranche 2 commence in Australia?", "acceptedAnswer": { "@type": "Answer", "text": "Tranche 2 AML/CTF obligations commence on 1 July 2026. All reporting entities in designated sectors including lawyers, accountants, real estate agents, conveyancers, and trust and company service providers must have their AML/CTF programs in place by this date." } } ] }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Free Resources", "item": "https://www.headstartdocs.com.au/tranche-2-resources" }, { "@type": "ListItem", "position": 3, "name": "AML/CTF: Not Just for Property Lawyers", "item": "https://www.headstartdocs.com.au/tranche-2-resources/designated-services-not-just-property" } ] }, { "@context": "https://schema.org", "@type": "Article", "headline": "AML/CTF: Not Just for Property Lawyers — Designated Services Every Practice Should Review", "description": "The new AML/CTF regime captures far more than conveyancing. Designated services include company transfers, trust creation, debt financing, nominee arrangements and more. Every Australian law society has published guidance to help practices prepare before 1 July 2026.", "datePublished": "2026-02-25", "dateModified": "2026-02-25", "url": "https://www.headstartdocs.com.au/tranche-2-resources/designated-services-not-just-property", "image": "https://www.headstartdocs.com.au/logo-512.png", "inLanguage": "en-AU", "isPartOf": { "@type": "WebSite", "name": "HeadStart Docs", "url": "https://www.headstartdocs.com.au" }, "about": { "@type": "Thing", "name": "AML/CTF Compliance", "description": "Anti-Money Laundering and Counter-Terrorism Financing compliance for Australian businesses under Tranche 2" }, "author": { "@type": "Organization", "name": "HeadStart Docs" }, "publisher": { "@type": "Organization", "name": "HeadStart Docs", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png" } } }, { "@context": "https://schema.org", "@type": "FAQPage", "mainEntity": [ { "@type": "Question", "name": "What are designated services under the AML/CTF Act for lawyers?", "acceptedAnswer": { "@type": "Answer", "text": "Designated services include buying, selling or transferring a body corporate or trust, raising money by equity or debt financing, creating or restructuring a body corporate or trust, selling shelf companies, acting as or arranging nominee directors or shareholders, providing registered office addresses, and receiving or controlling client money, accounts or property to help plan or execute transactions." } }, { "@type": "Question", "name": "Does the QLS have an AML/CTF hub?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. The Queensland Law Society has an AML/CTF resource centre at qls.com.au with practitioner guidance, Proctor magazine articles and advocacy updates. QLS has been advocating on AML/CTF matters since 2007." } }, { "@type": "Question", "name": "Where can I find my state law society's AML/CTF guidance?", "acceptedAnswer": { "@type": "Answer", "text": "Every Australian state and territory law society has published a dedicated AML/CTF hub or resource page. These include the QLS (Queensland), Law Society of NSW, Law Institute of Victoria, and the law societies of SA, WA, Tasmania, the ACT and the NT. The Law Council of Australia also provides national-level guidance." } }, { "@type": "Question", "name": "Are commercial lawyers captured by AML/CTF obligations?", "acceptedAnswer": { "@type": "Answer", "text": "Yes, in many cases. Designated services include buying or selling companies, creating or restructuring trusts and companies, arranging debt or equity financing and acting as nominee directors. These activities are common in commercial, corporate and advisory practices." } }, { "@type": "Question", "name": "When do AML/CTF obligations start for lawyers in Australia?", "acceptedAnswer": { "@type": "Answer", "text": "AML/CTF obligations for legal practitioners commence on 1 July 2026. AUSTRAC enrolment opens 31 March 2026, and practices must enrol within 28 days of providing a designated service." } } ] } ] --- [Get Started ](/checkout) We use cookies to enhance your experience and analyse traffic. [Privacy Policy](/privacy) Essential OnlyAccept All [Skip to main content](#main-content) [ ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) ](/) [Home ](/) Features [Programs ](/programs) Resources Sectors [Log in ](/auth) [Portal](/aml-landing) ![Legal team reviewing AML/CTF compliance requirements](/assets/law-practice-office-team-DxjvVhw2.jpg) [Back to Free Resources](/tranche-2-resources) 25 February 2026 • Law Practices # AML/CTF is not just for property lawyers Understanding exactly what designated services you may offer is a crucial first step to determine whether your practice is in or out of the new AML/CTF regime. The breadth of these services means many practices — not just those in conveyancing — may find themselves captured for the first time. ## Understanding the AML/CTF reforms AUSTRAC has published an overview of how the AML/CTF laws are changing and what the reforms mean for newly captured sectors, including legal practitioners. Source: AUSTRAC, How Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws are changing (August 2025) ## Designated services go well beyond real estate Designated services include a wide range of activities involving a body corporate such as a company or trust, and transactional assistance. These services may capture everyday legal work across commercial, corporate, charitable and private client practices. In addition to real estate transactions, designated services include: ### Designated services for legal practitioners - **Buying, selling, or transferring a body corporate or legal arrangement** (e.g. companies, trusts) - **Raising money by equity or debt financing** for a body corporate or legal arrangement - **Creating or restructuring** a body corporate or legal arrangement - **Selling or transferring a shelf company** - **Acting as, or arranging for someone to act in, certain positions** of a body corporate or legal arrangement (e.g. director, secretary, trustee) - **Acting as, or arranging for someone to act as, a nominee shareholder** of a body corporate or legal arrangement - **Providing a registered office address** for a body corporate or legal arrangement - **Receiving, holding, or controlling money, accounts, securities, virtual assets, or other property** to help a client plan or execute a transaction ## Which practice areas are affected? The breadth of these designated services means many practices, particularly those in the following areas, may find themselves captured by AML obligations for the first time: ### Corporate law Company formations, restructures, share transfers, M&A transactions ### Commercial advisory Equity and debt financing, business acquisitions, joint ventures ### Private client work Family trusts, discretionary trusts, asset structuring, wealth management ### Trusts and estates Trust establishment, estate administration involving entity or property transfers ### General practice Practices handling client money or facilitating transactions across multiple areas ### Charitable sector Establishing or restructuring charitable trusts, DGR entities, or not-for-profit structures ### Even one designated service triggers obligations Providing only one designated service will result in the practice being classified as a reporting entity. This makes it critical that practitioners begin a thorough review before the new regime commences on 1 July 2026. ## Next steps to consider 1. **Map your services** against the designated service categories listed above 2. **Document whether you are in or out** of the new regime — this is a decision your practice needs to make and record 3. **Assess which teams or practice areas** may require new AML/CTF policies, procedures and training 4. **Develop your AML/CTF program** before obligations commence on 1 July 2026 5. **Enrol with AUSTRAC** — enrolment opens 31 March 2026 ## Assessing your ML/TF risks Once you've determined whether your practice provides designated services, the next step is assessing your money laundering and terrorism financing risks. AUSTRAC has published guidance on how reporting entities should approach this. Source: AUSTRAC, How Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws are changing (August 2025) ## State and territory law society AML/CTF hubs Every Australian state and territory law society has published dedicated AML/CTF resources to help practitioners prepare. These hubs include guidance notes, CPD courses, FAQs and practical compliance tools. [ ### Queensland Law Society (QLS) Resource centre with practitioner guidance, Proctor magazine articles and advocacy updates. QLS has been advocating on AML/CTF since 2007. ](https://www.qls.com.au/resource-centre/anti-money-laundering-counter-terrorism-financing)[ ### Law Society of NSW Multi-page hub with overview, FAQs, on-demand interactive CPD courses and resources. Featured an information session with the AUSTRAC CEO. ](https://www.lawsociety.com.au/practising-law-NSW/AML-and-CTF-Hub)[ ### Law Institute of Victoria (LIV) "One-stop shop" hub with AML foundations course, APLYiD trial for client onboarding, supervision and ethics courses. ](https://www.liv.asn.au/amlhub)[ ### Law Society of South Australia Six-part CPD webinar series, FAQs, links to AUSTRAC Core Guidance, and legislative timeline updates. ](https://www.lawsocietysa.asn.au/site/site/for-legal-practitioners/resource-hubs/anti-money-laundering-and-counter-terrorism-financing.aspx)[ ### Law Society of Western Australia 10-step practical guide with timing benchmarks, CPD education series, AML/CTF Countdown Conference, and FAQs. ](https://lawsocietywa.asn.au/resource-centre/practising-resources/aml-ctf-hub/)[ ### Law Society of Tasmania Compliance checklist, Guidance Notes covering criminal law obligations through to client due diligence, and preparation articles. ](https://www.lst.org.au/anti-money-laundering-counter-terrorism-financing/)[ ### Law Society of the ACT Obligations overview, Legal Professional Privilege guidance, privacy implications, templates and AUSTRAC e-learning links. ](https://www.actlawsociety.asn.au/practising-law/aml-ctf-1)[ ### Law Society of the Northern Territory Seven detailed Guidance Notes, practical workshops, ethics CPD events and participation in the LCA AML/CTF Working Group. ](https://lawsocietynt.asn.au/index.php/2024/07/29/anti-money-laundering-counter-terrorism-financing/) ### National bodies [ ### Law Council of Australia Federal policy and advocacy body. Published the AML/CTF Red Flags List for Legal Practitioners and coordinates the national AML/CTF Working Group. ](https://www.lawcouncil.asn.au/policy-agenda/regulation-of-the-profession-and-ethics/anti-money-laundering)[ ### AUSTRAC The regulator. Provides the Legal Profession Program Starter Kit, Core Guidance, new AML/CTF Rules, sector-specific guidance, and the enrolment portal. ](https://www.austrac.gov.au/amlctf-reform) [ Read our complete Tranche 2 Guide Key dates, affected sectors, obligations and how to prepare ](/tranche-2) ### Law Practice AML/CTF Program HeadStart Docs offers a Law Practice Edition with policies, procedures, risk assessment tools and training materials tailored to legal professionals under Tranche 2 — covering all designated services, not just conveyancing. 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