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
- Map your services against the designated service categories listed above
- Document whether you are in or out of the new regime — this is a decision your practice needs to make and record
- Assess which teams or practice areas may require new AML/CTF policies, procedures and training
- Develop your AML/CTF program before obligations commence on 1 July 2026
- 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.
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.
Law Institute of Victoria (LIV)
"One-stop shop" hub with AML foundations course, APLYiD trial for client onboarding, supervision and ethics courses.
Law Society of South Australia
Six-part CPD webinar series, FAQs, links to AUSTRAC Core Guidance, and legislative timeline updates.
Law Society of Western Australia
10-step practical guide with timing benchmarks, CPD education series, AML/CTF Countdown Conference, and FAQs.
Law Society of Tasmania
Compliance checklist, Guidance Notes covering criminal law obligations through to client due diligence, and preparation articles.
Law Society of the ACT
Obligations overview, Legal Professional Privilege guidance, privacy implications, templates and AUSTRAC e-learning links.
Law Society of the Northern Territory
Seven detailed Guidance Notes, practical workshops, ethics CPD events and participation in the LCA AML/CTF Working Group.
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.
AUSTRAC
The regulator. Provides the Legal Profession Program Starter Kit, Core Guidance, new AML/CTF Rules, sector-specific guidance, and the enrolment portal.
Read our complete Tranche 2 Guide
Key dates, affected sectors, obligations and how to prepare
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.