AML/CTF compliance
Tranche 2 Is Live. What Every Law and Conveyancing Firm Must Have in Place Now
26 September 2026 · 5 min read
In brief
Since 1 July 2026, Australian law and conveyancing firms that provide a designated service must meet AML/CTF obligations including AUSTRAC enrolment, an approved compliance program, customer due diligence, ongoing monitoring, reporting and record keeping.
On 1 July 2026, Australia's anti-money laundering and counter-terrorism financing (AML/CTF) regime expanded to cover lawyers, conveyancers, accountants, real estate professionals, and dealers in precious stones and metals. AUSTRAC says the regulated population will grow from around 19,000 businesses to almost 100,000.
If your firm provides a "designated service", you are now a reporting entity. For legal practices, designated services include:
Conveyancing is at the centre of this list.
- assisting clients to buy, sell or transfer real estate
- assisting clients to buy, sell or transfer entities or legal arrangements
- receiving, holding, controlling or managing client property while assisting with a transaction
- assisting with equity or debt financing transactions
- selling or transferring shelf companies
- creating or restructuring entities or legal arrangements
- acting as, or arranging, a director, secretary, attorney or nominee shareholder
- providing a registered office or principal place of business address
What you must do
1. Enrol with AUSTRAC. Enrol within 28 days of starting to provide a designated service. For services that became regulated on 1 July 2026, AUSTRAC set the deadline at 29 July 2026. If you missed it, act now.
2. Have an AML/CTF program. The program includes:
Senior management must approve it, it must be kept up to date, and it must be independently evaluated at least every three years.
3. Appoint an AML/CTF compliance officer. This person manages day-to-day compliance and makes sure the procedures are actually followed.
4. Screen and train your people. You must do personnel due diligence and give staff AML/CTF training so they can recognise and escalate risk.
5. Do customer due diligence (CDD). Before providing the service, establish who your client is and check them against sanctions and politically exposed person (PEP) lists. Then keep monitoring through the relationship.
6. Report to AUSTRAC. Depending on what you do, this may include:
7. Keep records for at least seven years.
- an ML/TF risk assessment covering your money laundering, terrorism financing and proliferation financing risks
- documented policies, procedures, systems and controls to manage those risks
- suspicious matter reports (SMRs)
- threshold transaction reports (TTRs) for cash of $10,000 or more
- international funds transfer instructions (IFTIs)
- cross-border movement reports (CBMs)
Why it matters
The AML/CTF Act allows civil penalties of up to 100,000 penalty units per contravention for a company and 20,000 penalty units for an individual. AUSTRAC has said its early enforcement focus for newly regulated businesses will be on those who wilfully ignore their obligations, not those making genuine efforts. The key word is genuine: you need to be able to show the effort.
How Comply.LM helps
Comply.LM was built for Australian legal and conveyancing firms:
Your team keeps practising law, and the compliance trail builds itself in the background.
General information only, not legal advice. Check your specific obligations with AUSTRAC guidance or your professional adviser.
- guided AUSTRAC enrolment
- automated identity, address and sanctions checks
- traffic-light risk scoring for each client
- a single place for your risk assessment and compliance records
- every decision timestamped and attributed, so you are audit-ready by default
Authoritative sources
This article draws on current AUSTRAC guidance. Always check the source guidance for updates that apply to your circumstances.
Common questions
Does every Australian law firm need to enrol with AUSTRAC?
No. The obligations apply when a firm provides one or more designated services with the required Australian connection. Firms should assess their actual services against AUSTRAC guidance.
When did Tranche 2 obligations start for law firms?
The obligations for newly regulated services started on 1 July 2026. AUSTRAC stated that 29 July 2026 would typically be the enrolment deadline for businesses already providing those services.