Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws

Recent updates to Australia’s federal Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws mean that from 1 July 2026 all Australian law firms are required to collect and verify certain client information before providing legal services.

These changes apply across the legal profession and are designed to strengthen safeguards within the financial and legal systems. This has created some important changes to our client onboarding and verification process.

Why are we asking for identification and other information?

Australian law now requires law firms, accountants, conveyancers and real estate professionals to comply with anti-money laundering and counter-terrorism financing (AML/CTF) laws.

As part of these obligations, we may ask you to provide documents and information that confirm your identity and help us understand the nature of the transaction or matter in which we are acting for you. This process is often referred to as Verification of Identity (VOI) and Know Your Customer (KYC).

VOI confirms that you are who you say you are.

KYC goes further and may require information about the source of funds, the purpose of a transaction, and the people who ultimately own or control an entity such as a company or trust.

These requirements are a legal obligation and form part of the broader AML/CTF framework. They help protect clients, professional advisers and the community by reducing the risk of fraud, financial crime and identity misuse.

We appreciate your cooperation. Any information you provide will be handled confidentially and used only for the purposes required by law and the provision of our legal services.

We are attempting to make this process as straightforward as possible for those of our clients who are impacted by the changes. We’ve introduced a secure online method where you can quickly provide the required details, so that we can act for and assist you. This is necessary for us to meet our obligations while keeping the process efficient and convenient for you.

We understand that providing additional information can be an inconvenience, and we appreciate your cooperation. These steps allow us to continue acting for you and delivering our services without interruption.

If you have any questions about these changes, please contact our team at mail@genders.com.au.

Thank you for your understanding and continued trust in our firm.

What is changing

The Federal Parliament passed reforms in November 2024 that expand Australia’s anti-money laundering and counter-terrorism financing regime. From 1 July 2026, the regime will cover a new set of professions. The Australian Transaction Reports and Analysis Centre (AUSTRAC) is the regulator. AUSTRAC has overseen banks, casinos and remittance providers for years; the difference now is that everyday professional services are being added to the list.

The reforms align Australia with international standards set by the Financial Action Task Force (FATF). They bring our regime closer to the rules already in place in the UK, US, EU, and New Zealand. Australia has been an outlier on this. The reforms bring us into line.

If you have engaged a lawyer, accountant, conveyancer or real estate agent recently, you may already have been asked for more identification than usual. From 1 July 2026, those requests become standard practice across the legal profession. Your advisers must now verify who you are. They will also ask about the source of funds in your transactions and about how your business, company or trust is structured.

This is part of the biggest expansion of Australia’s anti-money laundering rules in almost twenty years. It changes how a lot of professional services are delivered. If you own a business, hold investments, transfer assets, or act as a trustee, the change will affect how your advisers engage with you. The same goes if you are in the middle of a property or business sale, and possibly if you deal with a deceased estate.

Who is now regulated

From 1 July 2026, the following professions will fall within AUSTRAC’s regulatory scope:

  • Lawyers;
  • Accountants and tax agents;
  • Real estate agents and property developers;
  • Conveyancers;
  • Dealers in precious stones, metals and products; and
  • Trust and company service providers.

Most established firms in these professions will be affected – sole practitioners, mid-sized firms, and national groups alike.

Which services are caught

Not every service these professionals provide is in scope. The rules apply only to what the legislation defines as ‘designated services’: services that help a client advance a specific transaction. In practical terms, that includes:

  • Forming companies, trusts and other entities;
  • Preparing transaction documents and contracts;
  • Holding or transferring client funds;
  • Acting on the sale or purchase of property or businesses; and
  • Acting on certain corporate restructures and asset transfers.

Routine advice that does not involve advancing a transaction sits outside the regime. Where the line falls in practice is a judgement your adviser will need to make on each transaction.

What firms now have to do

Every regulated firm will need to:

  • Enrol and register with AUSTRAC, and appoint an internal AML/CTF Compliance Officer;
  • Carry out a money laundering and terrorism financing risk assessment;
  • Develop and maintain a written AML/CTF policy;
  • Conduct initial and ongoing customer due diligence on clients;
  • Report suspicious transactions, threshold transactions and certain international transfers to AUSTRAC;
  • Keep secure records of customer identification and transaction activity; and
  • Ensure their board or senior management takes active oversight responsibility.

This is a substantial body of compliance to build from scratch. It will take many months for the professions to work out how to implement these changes with a minimum of friction.

What this means for you

The change you will notice most is at the start of a new engagement. When you engage a lawyer, accountant, real estate agent or conveyancer after 1 July 2026, expect to be asked to:

  • Provide more identification than you may have in the past, often through a digital identity verification service such as InfoTrack;
  • Answer questions about the ownership structure of any company or trust involved;
  • Confirm the nature and purpose of the work you want your adviser to do;
  • In some cases, confirm the source of the funds being used in a transaction; and
  • If you operate through a trust, a company group, or a layered structure, expect more questions than someone transacting in their own name. The compliance task scales with the complexity of the structure.

The other practical change is that a firm will sometimes need to pause an engagement. That happens if it cannot satisfy itself about who you are, or where the funds are coming from. This will be rare. It is now a legal requirement, not a discretionary judgement.

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