Robbie Goldberg

Country Director, Australia at Legl

On 1 July 2026, Australia's anti-money laundering and counter-terrorism financing (AML/CTF) regime formally extended to law firms for the first time. The long-anticipated "Tranche 2" reforms to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (the AML/CTF Act) bring lawyers, accountants, conveyancers, real estate professionals, trust and company service providers, and dealers in precious metals and stones under the supervision of the financial intelligence regulator, AUSTRAC. The regulator's message on commencement was blunt: in its 1 July announcement, chief executive Brendan Thomas said "the laws are now in force – the expectation is compliance, and the alternative is enforcement."

For practices that provide a "designated service," the preparation phase is over. The most pressing item on the calendar is now an enrolment deadline that falls at the end of this month.

The 29 July enrolment deadline

Any firm that began providing a designated service on 1 July must enrol with AUSTRAC within 28 days of first providing that service. For most firms that started on commencement day, that means a hard deadline of 29 July 2026. Enrolment is not a formality to be deferred — it is the mechanism by which AUSTRAC identifies reporting entities, and it applies regardless of firm size.

Thomas has tempered the enforcement rhetoric with a measure of reassurance, noting that AUSTRAC "has never penalised a small business for administrative mistakes" and that support remains available — including a dedicated contact centre for newly regulated entities. But the goodwill extends to genuine effort, not inaction: the obligation to begin complying has already started.

What counts as a "designated service"

A crucial feature of Tranche 2 is that it does not regulate lawyers as a profession — it regulates specific activities. The new professional services table at subsection 6(5B) of the AML/CTF Act ("Table 6") lists nine designated services, including assisting a client to buy, sell or transfer real estate; helping to buy, sell or transfer a company or trust; receiving, holding or managing client money or property as part of a transaction; assisting with equity or debt financing; and acting as, or arranging for someone to act as, a director, trustee or nominee shareholder.

As the Law Society of NSW explained in guidance published in February 2026, whether a practice is captured "depends on whether the practice provides one or more designated services." Notably, pure litigation and advisory work generally falls outside the net. Advice that merely "influences a client's thinking" — strategic guidance, background analysis, or advice on legal consequences — will usually not be enough to trigger obligations; the assistance must directly advance a transaction. AUSTRAC's guidance also confirms that even one-off, low-volume or unpaid work can be captured, so firms cannot assume that infrequent conveyancing or corporate work sits safely out of scope.

New forms, and conduct rule changes

Two practical developments accompany commencement. First, AUSTRAC's new threshold transaction report (TTR) and suspicious matter report (SMR) forms are now the live versions in AUSTRAC Online, replacing the drafts previewed in June. Compliance officers should confirm that whoever handles reporting knows where to find them and how they differ from earlier versions.

Second, the Law Council of Australia amended the Australian Solicitors' Conduct Rules (ASCR) — published on 19 June 2026 and commencing 1 July 2026 — with changes directly connected to the AML/CTF reforms. Firms should read these alongside their AML/CTF obligations rather than treating professional conduct and financial-crime compliance as separate workstreams.

The compliance workload ahead

For many mid-sized and boutique firms, this is the first time they have had to run customer due diligence before acting, screen clients for sanctions and politically exposed persons, appoint an AML/CTF compliance officer, maintain a two-part written AML/CTF programme, and keep records for seven years. Division 8 of the AML/CTF Rules 2025 does allow a firm to rely on another reporting entity — such as a conveyancer or real estate agent — to collect and verify know-your-client information, provided the arrangement is documented and reassessed at least every two years. Technology platforms such as Legl are among the tools firms use to manage client onboarding, due diligence and record-keeping at scale.

Key Takeaways

  • Enrol on time. Enrol with AUSTRAC within 28 days of first providing a designated service — for most firms, by 29 July 2026.
  • Map your services. Assess your practice against Table 6 (subsection 6(5B)); it is activities, not job titles, that trigger obligations, and even one-off work can be captured.
  • Update your reporting. Make sure reporting staff are using AUSTRAC's new live TTR and SMR forms in AUSTRAC Online.
  • Read the ASCR changes together with your programme. The 1 July conduct rule amendments are connected to AML/CTF, not separate from it.
  • Document your reasoning. Keep records of your designated-services assessment even if you conclude you are not captured — record-keeping expectations apply either way.

Looking Ahead

With commencement behind them, firms should expect AUSTRAC's focus to shift from education towards supervision over the coming months, and the regulator's stated willingness to distinguish "administrative mistakes" from genuine non-compliance will be tested in practice. Practices that have not yet completed a designated-services assessment should treat it as the immediate priority. The next milestones to watch are AUSTRAC's first post-commencement guidance updates and any early signal of how it intends to engage with the newly regulated professions.

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