Law Council of Australia

Policy Agenda

AML/CTF regulation and the legal profession

On 1 July 2026, members of the Australian legal profession that provide ‘designated services’ became subject to the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), as amended by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) (collectively, the AML/CTF Act).

The impact of the new framework on the legal profession is a key advocacy focus of the Law Council and especially its Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) Working Group. The Law Council and the AML/CTF Working Group are continuing to work to ensure the new framework is appropriately tailored to the unique circumstances of the legal profession, including by working with AUSTRAC and other regulatory agencies and departments regarding aspects of the regime that fall within their purview, such as the Office of the Australian Information Commissioner. This work has included the production of National Legal Profession AML/CTF Guidance Notes, which are intended to support practitioners to understand the new legislative regime and their obligations under it.

This webpage brings together links to resources regarding the new legislative regime, compiling guidance, commentary, and tools from AUSTRAC and other regulators, the Law Council’s constituent bodies, and other relevant entities. These resources are intended to assist legal practitioners in understanding and navigating the new legislative regime, and successfully implementing their obligations under it.

While the Law Council will review and update this webpage regularly, some materials linked may become outdated. Practitioners are encouraged to independently confirm the accuracy and currency of information by cross referencing it with AML/CTF Act and associated materials, and with official regulatory guidance, and to raise any questions or concerns with your local State or Territory law society or law institute, or bar association. 

Understanding the new AML/CTF framework

AML/CTF framework guidance

For information about the recently amended AML/CTF framework and to understand how it applies to the legal profession, we recommend the following resources:

Privacy guidance

All legal practices that are reporting entities under the AML/CTF Act are subject to the Privacy Act 1988 (Cth) (Privacy Act) in relation to their AML/CTF Act obligations, including practices that fall within the definition of a ‘small business’ (though small businesses will remain not subject to the Privacy Act in relation to their non-AML/CTF activities).

The OAIC has developed regulatory guidance to assist newly regulated reporting entities to understand their obligations under the Privacy Act and how they interact with their obligations under the AML/CTF Act, which are available here:

Sanctions guidance

All Australian legal professionals are required to comply with Australian sanction laws, which comprise targeted financial sanctions (TFS) and restrictions on certain goods, services, and commercial activities. These laws may, depending on the specific framework, prohibit you from providing services to a person/s or entity/s subject to sanctions. Legal professionals are also prohibited from providing legal services in connection with a sanctioned supply or certain other sanctioned services or in relation to certain sanctioned commercial activities under regulation 5 and regulations 5A-5CA respectively of the Autonomous Sanctions Regulations 2011 (Cth).

The AML/CTF Act imposes obligations in relation to Australian sanctions laws that you need to be aware of. For example, reporting entities are required to check whether a customer (client) is a person designated for TFS when conducting initial client due diligence under section 28.

The Australian Sanctions Office (ASO) has produced resources to assist you with understanding Australia’s sanctions laws and your sanctions obligations, including on sanctions compliance for legal professionals:

AUSTRAC has also produced guidance on your sanctions obligations in the context of the AML/CTF Act:

Am I regulated?

We recommend consulting the AML/CTF Act and its supporting material in the first instance to work out whether you provide a designated service, or you may wish to use one of the following quick tools:

If you need more detailed guidance, we recommend that you consult AUSTRAC’s Professional designated services guidance, which provides AUSTRAC’s interpretation of the scope of application of the professional services designated services in table 6, section 6(5B) of the AML/CTF Act, and the Law Council’s National Legal Profession AML/CTF Guidance Note 4.

There are a number of other helpful resources available that will assist you in working out whether you are regulated:

What are my obligations?

Reporting entities are subject to a number of obligations under the AML/CTF Act and the Privacy Act.

AML/CTF obligation

The AML/CTF Act imposes a range of obligations on reporting entities, including to:

Detailed guidance on these obligations is available here:

Privacy Act obligations

The OAIC’s regulatory guidance, Privacy Guidance for reporting entities under the AML/CTF Act explains what the Privacy Act’s obligations are and how they interact with their obligations under the AML/CTF Act. The OAIC has also produced other helpful resources regarding Privacy Act obligations:

The Queensland Law Society’s Privacy Compendium (SME Firm) is also an excellent resource that summarises material prepared by third parties, including the OAIC, developed to assist small law firms in Queensland to understand and implement their privacy obligations under the Privacy Act. It is of broader interest owing to the national application of the Privacy Act.

Implementation: Starter Kits, templates, and guides

All legal practices that are reporting entities are required to comply with the AML/CTF Act and the Privacy Act, in addition to Australian sanctions law, which requires the development and implementation of appropriate compliance frameworks.

This section provides information about how to implement your obligations, along with links to resources that will assist you in doing so.

Readiness checklist

Before you start thinking about how you are going to implement your AML/CTF obligations, we recommend reviewing the following resources to get an understanding of what you need to do to comply with regime:

Creating and implementing an AML/CTF Program

A critical piece of any AML/CTF compliance framework is the AML/CTF Program, which comprises a ML/TF/PF risk assessment, and AML/CTF policies. Reporting entities must have an AML/CTF program in place before providing a designated service.

The following resources will help you design and implement an AML/CTF program appropriate for all kinds of legal practice.  

Sole and small legal practices

AUSTRAC has developed profession specific Starter Kits that provide small businesses and practices with a free, customisable AML/CTF compliance framework, comprising a ML/TF/PF risk assessment, AML/CTF policies and processes, and forms.

The Starter Kit for the legal profession is designed for legal practices with the specific characteristics listed on the ‘Legal profession program starter kit: Getting started’ webpage. If your practice meets these characteristics, implementation of the kit will be aligned with Australian legal requirements and will satisfy AUSTRAC’s regulatory expectations of an appropriate AML/CTF program. You should still always consider whether the kit needs to be adapted to suit your practice, to ensure that it reflects the size, nature, and complexity of your practice.

If your practice does not meet all of the characteristics, you can still use the Starter Kit—you will just need to ensure that you have identified changes that you need to make to ensure that the AML/CTF Program you implement is appropriate to the size, nature, and complexity of your practice, and reflective of the ML/TF/PF risks faced.

The Starter Kit for the Legal Profession is available here, and the Starter Kit for the Conveyancing Sector is available here.

Additional resources that may be of assistance are:

The Law Society of New South Wales has developed Implementation Guide for sole and small practices to help with the practical implementation of the Starter Kits. The Guide is designed to complement AUSTRAC’s Starter Kits, and so should be used alongside it.

Medium and large legal practices

AUSTRAC’s Starter Kits are designed for small legal practices with the specific characteristics listed on the ‘Legal profession program starter kit: Getting started’ webpage. Legal practices that do not meet these characteristics may still use it, but will need to adapt it to ensure that the AML/CTF Program you implement is appropriate to the size, nature, and complexity of your practice, and reflective of the ML/TF/PF risks you may face.

If your practice differs significantly from the characteristics of the practice the Starter Kit is designed for, you may wish to refer to the Implementation Guide for medium and large practices designed by the Law Society of New South Wales, which is intended to cater to practices that are too large and/or more complex than the practices the AUSTRAC Starter Kits are intended for. The Implementation Guide for medium and large practices aims helps firms design and implement their own bespoke AML/CTF programs, rather than to implement AUSTRAC Starter Program.

Privacy compliance

The OAIC has created a range of tools and resources, including template documents, to assist newly regulated reporting entities to comply with their obligations under the Privacy Act:

The Law Council’s Constituent Bodies have also created several helpful resources to assist legal practices with understanding and complying with their obligations:

Sanctions compliance

The ASO and AUSTRAC have created several resources to assist entities with complying with Australian sanctions law:

Clients, costs, and conduct rules

Clients engagement and retainers

When entering into a retainer with a client, solicitors need to make clients aware of how the AML/CTF Act might impact the provision of legal services, and clients need to acknowledge and agree that legal services received are provided subject to solicitors obligations under that Act and their professional responsibilities and ethical duties.

Costs

Conduct rules

The Australian Solicitors’ Conduct Rules and Commentary have been updated to support the commencement of the AML/CTF regime by clarifying the scope of the ASCR and the expectation that solicitors inform clients about termination of retainer agreements.  

Constituent body resources and practitioner questions

AUSTRAC

AUSTRAC’s Contact Centre is available to answer questions and provide guidance to reporting entities and other stakeholders about AML/CTF obligations. Queries can be submitted online or by phone to 1300 021 037.

Constituent Body resources

The ACT Law Society can be reached by phone (02) 6274 0300, 9:00 am – 12:30 pm, Monday to Friday, or by email to mail@actlawsociety.asn.au.

The Law Society of New South Wales has an AML/CTF hub available on their website.

The Law Society operates a dedicated AML/CTF Professional Support Unit that can be reached by calling (02) 9926 0249 or by email at amlctf@lawsociety.com.au.

The Law Society of the Northern Territory has an AML/CTF resource page.

Queensland Law Society’s has an Anti-Money Laundering / Counter Terrorism Financing resource centre available on their website.

Queries may be directed to QLS via phone to 1300 367 757 between 8:30 pm – 5:00 pm, Monday to Friday, or to the QLS Ethics and Practice Centre, which provides legal ethics and practice support guidance and education to QLS members by phone to (07) 3842 5843 or by email to ethics@qls.com.au

AML/CTF related queries can be directed to the Law Society of South Australia’s Ethics and Practice Unit, which is available to provide members of the legal profession with general guidance in relation to ethical issues and professional obligations. The team can be reached by phone at (08) 8229 0229, or by email to ethicsandpractice@lawsocietysa.asn.au (include ‘Ethics Inquiry’ in the subject line.)

The Law Institute of Victoria has an AML/CTF Hub on its website and operates an AML/CTF Helpline that can be reached by calling (03) 9607 9330 or by email to aml@liv.asn.au.

The Law Society of Tasmania has an AML/CTF Hub on its website.

General queries can be made to (03) 6234 4133

The Law Society of Western Australia has an AML/CTF Hub on their website.

Queries can be made by phone to (08) 9324 8600, or by email to info@lawsocietywa.asn.au.

Get in touch

If you would like to contact us regarding this webpage, please email mail@lawcouncil.au.

Last Updated on 30/10/2026

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