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Tranche 2 — obligations from 2026

Legal professionals

Law firms providing certain designated services — property, company formation, trust services — become reporting entities under Tranche 2.

AML/CTF Amendment Act 2024 — Designated Non-Financial Businesses

AML/CTF Obligations

Enrol with AUSTRAC and implement a full AML/CTF program for designated legal services

Conduct client due diligence at the commencement of every matter involving a designated service

Verify the beneficial ownership and control of corporate or trust clients

Monitor client trust account transactions for suspicious patterns

Lodge SMR reports within 3 business days of forming a suspicion

Train all staff providing designated services in AML/CTF obligations

Required reports:SMR

Law firms must lodge SMR reports within 3 business days of forming a suspicion in connection with a designated service. Legal professional privilege applies narrowly and does not provide a blanket exemption from SMR obligations.

Typical Customer Risk Profiles

1

Clients seeking rapid corporate structure creation — a client who wants a company or trust formed quickly, with minimal questions asked about ownership, is a recognised red flag for ML structuring.

2

Clients with complex offshore ownership — instructions from clients whose ultimate beneficial owners are in high-risk jurisdictions, or who use multiple offshore vehicles, require enhanced scrutiny.

3

High-value property transactions with cash components — any matter where the client is contributing a significant amount of cash to a property purchase requires documented source of funds verification.

4

Trust account deposits from unexpected sources — a trust account receipt from a third party not connected to the matter, or for an amount inconsistent with the transaction value, is a serious red flag.

Recommended Compliance Pack

Legal Pack

Pre-configured for Legal professionals — KYC rules, risk thresholds, AUSTRAC report templates, CDD workflows, and monitoring rules aligned to your obligations. Ready from day one.

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What's included

System default — customisable

Matter-based CDD workflows — client intake, identity verification, and risk assessment at matter open

Beneficial ownership mapping for complex corporate and trust structures with UBO identification

Client trust account monitoring with configurable rules for unusual transaction detection

SMR preparation and case management tools for MLRO review and regulatory reporting

AML/CTF program template for law firms with matter risk assessment and staff training tracking

Example workflow

Default — you can modify steps
1

New matter opened

Matter involves a designated service? CDD check triggered automatically. Client intake form sent.

2

Client identity verified

Individual clients complete biometric KYC. Corporate clients go through KYB with UBO mapping.

3

Beneficial ownership confirmed

All directors and UBOs identified and verified. Sanctions and PEP screening applied.

4

Trust account monitored

Client funds received into trust. Amount and source checked against expected transaction value.

5

Risk reviewed at key milestones

Matter risk reviewed at key stages — unusual changes in scope, value, or parties trigger a re-check.

6

SMR or clean closeout

Suspicious activity? MLRO prepares SMR. Matter closed cleanly? Records retained for 7 years.

Pricing Recommendation

Recommended

Professional

Law firms handling corporate clients, trust accounts, and complex property matters need full beneficial ownership mapping, trust account monitoring, and MLRO case management workflows.

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Ready to get compliant as a Legal?

Your Legal Pack is configured on day one. 7-day free trial — no credit card, no consultants, no configuration sprints.