By the Law Society of WA
We are now less than a year away from the commencement of the tranche two reforms of the anti-money laundering and counter-terrorism financing (AML CTF) regime.
AUSTRAC, Australia’s AML CTF regulator, has begun an education campaign for the tranche two reporting entities, including lawyers.
Stage 1 includes AUSTRAC’s four introductory webinars for those new to the AML CTF framework. These webinars cover a general intro to AUSTRAC, an overview of AML CTF obligations, money laundering/terrorism financing risks and outsourcing. Registration for the August and September webinars is available here.
Stage 2 of AUSTRAC’s education campaign will start in October and will include more specific issues relevant to lawyers.
What’s next?
The AML CTF Rules are due to be published later this month, with core guidance to follow in October. Legal sector specific guidance is due in December, along with publication of starter program kits to assist smaller firms to design their AML CTF program.
While we wait for the final Rules and guidance, there are things you can do now to prepare your practice for AML CTF compliance, including
- considering your current clients and how you manage existing money laundering and terrorism financing risks to your practice
- reviewing the customer due diligence you do already and how this can be adapted for an AML CTF program
- looking at who to appoint as the AML CTF compliance officer in your firm
- documenting your policies and processes
A key issue for the legal profession is the costs of compliance with AML CTF obligations. In 2024, the Attorney-General’s Department published an Impact Analysis with estimates of the upfront and ongoing costs for the legal sector and other tranche two businesses. The estimate costs are below and a link to the full report is available on the Law Society’s AML CTF Hub.
The interaction between compliance with the AML CTF Act and Rules and our obligations as lawyers is complicated. The Law Society’s AML CTF Working Group, supported by our committees, continues to advocate on AML CTF consultations with directly with AUSTRAC via industry forums and through the Law Council of Australia. Many of the consultations are confidential and we share with you what we can.
Our own AML CTF education also continues with Fiona Halsey, Certified AML Specialist, providing an update on the reforms on 14 August 2025. Register here for the CPD webinar and read Fiona’s latest article in Brief.
For further updates, visit the Law Society’s AML CTF Hub and subscribe directly to AUSTRAC communications here. If you have concerns you would like us to raise on your behalf, please contact advocacy@lawsocietywa.asn.au.
