How new AUSTRAC anti-money laundering obligations will impact our clients

21/04/2026

Australian law firms, including Grifin Legal, will be subject to mandatory anti-money laundering (AML) and counter-terrorism financing (CTF) obligations from 1 July 2026, marking a significant expansion of the country’s financial crime prevention regime. The new laws bring legal practitioners into line with banks and financial institutions that have long operated under similar requirements. Known as the “Tranche 2” reforms, the new rules also capture accountants, real estate agents, conveyancers, and trust and company service providers.

From 1 July 2026, law firms providing “designated services” – such as managing client funds, establishing companies or trusts, or handling property transactions – will need to:

  • Conduct customer due diligence, including verifying client identities and identifying beneficial owners of legal structures;
  • Continuously monitor client activity and review changes to client information; and
  • Report various matters to AUSTRAC including suspicious activities, threshold transactions, cross-border movements.

Griffin Legal provides a range of legal services, but not all will be captured by AML/ CTF changes. Where we are assisting clients with property transactions, business sales, and corporate structuring work, the AML/CTF changes will impact our clients.

Clients can expect us to ask more questions and ID checks upfront, which may be a significant change. Keep in mind, this is now a legal requirement, not optional, and work typically cannot begin until these checks are completed.

The questions and checks we will undertake include:

  • Identification verification checks;
  • Questions about the source of funds and source of wealth;
  • Identifying whether an individual is a current or former politically exposed person;
  • Adverse media checks;
  • Considering complex structures in more details to identify who controls and benefits from the entity;
  • Continuously monitoring client activity and transactions that may require reporting; and
  • Refusing instructions or terminating the retainer if necessary in order to meet our AML/CTF obligations.

These obligations apply to every client engagement for the legal services mention above, including if we have worked with a client previously.

We expect some level of client frustration with this change, especially as real estate agents, accountants and banks may also be asking the same questions and undertaking the same checks. We will seek to minimise any disruption to ensure our services are provided as smoothly as possible.  We will provide more information to clients in the lead up to implementation. If you have questions, in the meantime please let us know.

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