Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime is undergoing its most significant expansion in nearly two decades. New legislation passed by the Federal Parliament will bring lawyers, accountants, conveyancers, real estate professionals and other “gatekeeper” professions within the scope of AML/CTF regulation for the first time.
The reforms are designed to strengthen Australia’s ability to detect and prevent money laundering, terrorism financing and other serious financial crimes.
The reforms will affect legal transactions undertaken by Queensland law firms and their clients from 1 July 2026.
Which Legal Services Will Be Subject to the AML/CTF Regime?
Not all legal work will fall within the new AML/CTF requirements. The legislation applies when a law firm provides certain “designated services” that are considered to present a higher risk of being used to facilitate money laundering or terrorism financing.
Generally, a law firm will be required to undertake customer due diligence and comply with AML/CTF obligations when assisting clients with transactions such as:
- Buying and Selling Real Property
- Managing Client Money
- Creating or Restructuring Companies
- Acting in Business Acquisitions and Sales
- Establishing and Managing Trusts
- Acting as a Nominee or Providing Registered Office Services
- Assisting with Large or Complex Financial Transactions
What Services Are Not Generally Captured?
Importantly, the AML/CTF regime is not intended to apply to all legal work. Services such as:
- Providing general legal advice;
- Representing clients in litigation or dispute resolution;
- Advocacy in courts and tribunals;
- Employment law advice;
- Family law advice;
- Criminal defence work; and
- Other purely advisory legal services
will generally not be designated services unless they are connected to a covered transaction or financial activity.
This distinction is designed to ensure that clients continue to have access to independent legal advice while targeting activities that are most vulnerable to misuse for money laundering purposes.
What Will Change for Clients?
Many clients will notice additional identification and verification requirements before we can commence working on certain matters.
Depending on the type of transaction, law firms may be required to:
- Verify the identity of individuals and companies.
- Identify beneficial owners of companies, trusts and other structures.
- Understand the purpose and nature of a transaction.
- Obtain information about the source of funds or source of wealth in higher-risk matters.
- Conduct ongoing due diligence throughout the life of a matter.
- Keep records of verification and due diligence activities.
What Information May Be Requested?
To comply with the new obligations, clients may be asked to provide:
For Individuals
- Passport or driver’s licence.
- Proof of residential address.
- Information regarding the purpose of the transaction.
- Evidence of the source of funds where required.
For Companies
- Company registration details.
- Details of directors and shareholders.
- Information identifying ultimate beneficial owners.
- Documentation supporting the transaction.
For Trusts
- Trust deeds and amendments.
- Details of trustees, appointors and beneficiaries.
- Evidence regarding the source of funds and assets where appropriate.
Providing this information early will help avoid delays and allow transactions to proceed smoothly.
How Will This Affect Property and Commercial Transactions?
Property and commercial transactions are expected to be among the areas most impacted by the reforms.
Law firms will have enhanced obligations to understand who they are acting for, where funds are coming from, and whether any aspects of a transaction raise money laundering concerns.
As a result, clients should expect:
- More comprehensive onboarding procedures;
- Additional requests for documentation, including providing information as to the source of funds; and
- Increased scrutiny of unusual transaction structures or funding arrangements.
How Macrossan and Amiet Is Preparing
Macrossan and Amiet is actively preparing for the introduction of the new AML/CTF framework. We have begun implementing updated client onboarding processes, increased verification procedures and new compliance systems to ensure we meet our regulatory obligations while continuing to provide efficient and practical legal services.
Our goal is to make the process as straightforward as possible for our clients.
What Should Clients Do Now?
There is no need for immediate action, but we encourage clients to:
- Ensure personal and business identification documents are current.
- Maintain records relating to company ownership and trust structures.
- Keep documentation regarding funding arrangements readily available.
- Be prepared for additional verification requests when engaging legal services from July 2026 onwards.
If you have any questions about how the AML/CTF reforms may affect your business, property transaction or legal matter, please contact our team.
