AUSTRAC’s AML/CTF Program Starter Kits are now available  

AUSTRAC, Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regulator, has released on its website AML/CTF Program Starter Kits (Starter Kits).  

Does your practice provide a designated service? 

On 1 July 2026, certain legal practices will become subject to obligations under the amended Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act).  

Legal practices are only subject to the obligations in the AML/CTF Act if they provide 'a designated service', as defined in the Act. In summary, a designated service includes assisting clients to: 

• Buy, sell or transfer real estate 
• Buy, sell or transfer legal entities 
• Receive, hold, control or manage their funds and/or property, for example, money, accounts, securities or assets 
• Sell or transfer a shelf company 
• Carry out some transactional work, including equity and debt financing 
• Create or restructure a legal entity or legal arrangement. 

A complete list of designated services is set out in section 6, Table 6 of the AML/CTF Act. AUSTRAC has issued guidance on its interpretation on what constitutes a designated service for professional services.  

AML/CTF obligations  

Legal practices that provide one or more designated services will become a ‘reporting entity’ and must enrol with AUSTRAC. New reporting entities will be able to enrol from 31 March and must do so within 28 days of commencing the provision of a designated service.  

By 1 July, AUSTRAC has stated that newly captured legal practices are expected to:  

• Have an AML/CTF program 
• Have an AML/CTF compliance officer  
• Have trained their staff on the AML/CTF program and internal processes, 
• Be ready to engage with clients and report suspicious matters. 

What is in the Starter Kits? 

For most legal practices, the Starter Kits can be adopted and implemented as a compliant AML/CTF program. The Starter Kits are designed to provide small practices with: 

• Information on how to conduct money laundering and terrorism financing risk assessments 
• AML/CTF policies and procedures to implement, including forms. 

While use of the Starter Kits is not mandatory, it is encouraged.

Coming soon: Legal Practitioner Implementation Guidance  

The Law Society of New South Wales is currently developing additional resources to assist legal practices use the Starter Kits, as well as guidance for larger firms on how to leverage the Starter Kits to develop AML/CTF programs that appropriately reflect the size, nature and complexity of their practices. 

Here to support you   

Practitioners seeking guidance on AML/CTF are encouraged to contact the Law Society of NSW’s Professional Support Unit on (02) 9926 0249 or email amlctf@lawsociety.com.au.