Do I need a separate AML/CTF program for conveyancing services?

Not necessarily as a separate document. If your firm provides designated legal and conveyancing services, its ML/TF risk assessment and AML/CTF policies must address the designated services it provides and the risks associated with them. The program should therefore identify and address each applicable service category without implying that a separate program is always required.

Can I use the AUSTRAC Starter Kit as my AML/CTF program?

The AUSTRAC Starter Kit is designed to help legal profession businesses develop their AML/CTF program. It must be adapted to the firm's designated services, ML/TF risks and controls. Using the unmodified Starter Kit does not by itself establish that the firm has met its obligation to develop and maintain an AML/CTF program appropriate to its business.

What are the penalties for law firms that don't comply with AUSTRAC?

For a contravention of an applicable civil penalty provision, the Federal Court may order a civil penalty. The statutory maximum can be 100,000 penalty units for a body corporate and 20,000 penalty units for a person other than a body corporate. At the $364 penalty-unit rate effective from 1 July 2026, those maxima are $36,400,000 and $7,280,000 respectively. These are maximum amounts a court may order, not automatic penalties for every instance of AML/CTF non-compliance. The applicable consequence depends on the provision contravened and the circumstances.

Does Tranche 2 apply to barristers?

Coverage is determined by the services a barrister actually provides, not by the professional title alone. A barrister who provides an applicable designated service may be a reporting entity, subject to the Act's conditions and exceptions. A barrister who does not provide a designated service is not brought into scope merely by being a barrister. Each practice should compare its actual services with the designated-service tables.

Can Klyvon help me write a Suspicious Matter Report?

Yes. Both plans include a suspicious matter report assistant. Enter the transaction date, transaction details and the suspicious elements observed, and Klyvon prepares a draft for review. The reporting entity remains responsible for ensuring the report is complete and accurate and for submitting it through AUSTRAC Online. Free includes a limited number of drafts per month; Essential provides a higher monthly allowance.

Does Klyvon include sanctions screening?

The AML/CTF Rules require AML/CTF policies to address controls that prevent prohibited dealings with assets connected to persons designated for targeted financial sanctions. Klyvon's generated program includes policy controls addressing targeted financial sanctions. Klyvon does not perform live sanctions-screening checks; the reporting entity remains responsible for implementing appropriate controls.

I started providing a designated service after 1 July 2026 — do I still need to enrol by 29 July 2026?

The 29 July 2026 transitional date applied to newly regulated entities already providing an applicable new designated service before 1 July 2026, and that date has passed. Under the standard rule, a person must apply to enrol no later than 28 days after starting to provide a designated service. Full explanation and worked examples: https://www.klyvon.com.au/austrac-enrolment-28-day-rule.

Updated August 2026

Field Guide · Lawyers & Law Firms

AUSTRAC AML/CTF compliance for lawyers and law firms

Tranche 2 is service-based, not entity-based. A sole practitioner doing property conveyancing may be captured; a litigation-only firm may not be. Whether particular information is subject to LPP requires assessment under the amended Act and the applicable law of privilege.

Build your firm's AML/CTF program →See the privilege split

7
Steps to compliance: 29 Jul
Enrolment deadline (passed): 3 days
Standard non-TF SMR deadline: $364
Penalty unit rate

Australian law firms may be regulated by AUSTRAC when they provide designated services; coverage depends on the services performed, not simply on being a lawyer or law firm. Where the obligations apply, firms must enrol, designate and notify an AML/CTF compliance officer, maintain an AML/CTF program, undertake initial and ongoing customer due diligence, train relevant personnel, retain required records and submit required reports. Legal professional privilege and tipping-off are separate considerations when suspicious-matter reporting arises.

⚠ The 29 July 2026 transitional enrolment deadline has passed · Standard enrolment is generally due within 28 days after starting a designated service · Compliance-officer notification is due within 14 days after designation; the historical transitional rule was the later of 29 July 2026 or 14 days after enrolmentaustrac.gov.au ↗

In this guide

Is your firm a reporting entity?What an in-scope firm must do LPP and tipping off What Klyvon generates Focused questions Get compliant with Klyvon

I. Service-Based, Not Entity-Based

Is your law firm a reporting entity?

Tranche 2 captures firms by the services they provide, not the type of practice they run.

In scope

Acting on a real property transaction
Managing or controlling client money or assets
Forming companies or trusts for clients
Acting as or arranging nominee directors/shareholders
Buying or selling a business entity or business assets
Providing registered office or company secretarial services

Generally not in scope

General litigation and dispute resolution
Criminal defence
Family law proceedings
Drafting wills and powers of attorney
Pure legal advice — no fund handling or transaction execution
Barristers providing advocacy services only

Not legal advice — confirm your specific services at austrac.gov.au ↗.

“A sole practitioner conveyancer is a reporting entity. A national litigation firm with no designated services is not. Scope is determined service-by-service.”
— AML/CTF Act 2006, designated services

If you are unsure whether your services are captured, check whether your business may be regulated. Firms that also provide conveyancing services can review the AML/CTF guide for conveyancers.

II. Operational Requirements

What an in-scope law firm must do

The existing obligations cover enrolment, governance, the firm’s AML/CTF program, customer due diligence, reporting, personnel training, record keeping and independent evaluation.

Confirm your designated services

Review the AML/CTF Act 2006. It is service-based, not entity-based. A sole practitioner doing property conveyancing is captured. A litigation-only firm may not be.

Enrol with AUSTRAC now if not enrolled

Appoint and notify your compliance officer

Designate an eligible individual at management level with sufficient authority, independence and access to resources and information. The individual must meet the applicable residency and fit-and-proper requirements. Notify AUSTRAC within 14 days after designation.

Build your AML/CTF Program

Customise to your firm's services and clients. The AUSTRAC Starter Kit must be tailored — an unmodified Starter Kit does not satisfy your program obligation.

Train relevant personnel

Provide initial and ongoing AML/CTF training to personnel who perform AML/CTF functions. Training must be appropriate to their functions, relevant ML/TF risks and responsibilities under your AML/CTF policies.

Apply CDD and meet reporting obligations

3 days / 24 hrs

Since 1 July 2026, undertake CDD in accordance with the Act and Rules, subject to applicable exceptions. Standard SMR deadlines are 3 business days after suspicion or 24 hours for terrorism-financing suspicions; partial-LPP cases may have a 5-business-day deadline and require an LPP form. Retain program, CDD and transaction records for their applicable statutory periods.

Schedule your independent evaluation

Where the Part 1A obligations apply, your evaluation frequency must be appropriate to the nature, size and complexity of the business and at least once every 3 years. Transitional rules stagger the first evaluation deadline for newly regulated entities.

See what an AML/CTF program contains, the AUSTRAC enrolment guide, and how to submit a Suspicious Matter Report to AUSTRAC.

III. LPP and Tipping Off

Does privilege protect my firm from having to file an SMR?

Amended section 41 provides specific treatment where some or all information grounding a suspicion is reasonably believed to be privileged.

f a reporting entity reasonably believes that some, but not all, information required in an SMR may be privileged, the privilege belongs to another person and the other statutory conditions apply, the report is due within 5 business days after the suspicion is formed and must be accompanied by the applicable LPP form. If the reporting entity reasonably believes that all information comprising the grounds for suspicion is privileged, it may refuse to give the report. Whether particular information is privileged depends on the circumstances.

“Section 123 applies where covered information is disclosed and the disclosure would or could reasonably be expected to prejudice an investigation. Statutory exceptions may apply, including the conditional crime-prevention exception for legal practitioners and legal-services businesses.”
— s.123, AML/CTF Act 2006

Tipping-off note

Section 123 makes it a criminal offence to disclose covered information where the disclosure would or could reasonably be expected to prejudice an investigation. Whether the test is met depends on what is disclosed, to whom and in what circumstances. The section contains exceptions, including a conditional exception for certain good-faith crime-prevention disclosures by legal practitioners and legal-services businesses.

IV. What You Get

Five documents, built for your specific firm

Not the unmodified AUSTRAC Starter Kit — documents adapted using your firm details, compliance officer and designated services.

AML/CTF Program

Firm-specific program covering legal professional privilege, tipping-off, SMR obligations, property transaction CDD, trust account controls, and your ML/TF risk assessment.

CDD Templates

Client due diligence procedures for individual clients, companies, trusts and beneficial owners, including controls for circumstances in which enhanced CDD is required.

Role-Based Staff Training + Certificate

Interactive initial and ongoing training tailored to each staff member's AML/CTF functions, relevant risks and responsibilities, with legal-sector scenarios covering red flags, tipping-off and SMR filing. Completion certificates provide evidence of training and are retained under the applicable program-record retention rule.

Compliance Officer Letter

A record of the firm's compliance-officer designation. The firm remains responsible for ensuring the designated individual meets the Act's eligibility, authority and independence requirements.

SMR Assistant

Klyvon prepares an SMR draft from the transaction details entered for review before submission. Standard deadlines are 3 business days after suspicion or 24 hours for terrorism-financing suspicions; separate LPP treatment may apply.

V. Focused Questions

Common questions from law firms

See the worked explanation of AUSTRAC’s 28-day enrolment rule.

Primary sources

AUSTRAC — Tranche 2 reform guidance

Last updated 20 August 2026 · Klyvon Compliance Team

VI. How Klyvon Helps

Compliance doesn’t end at enrolment — Klyvon runs alongside your practice

Klyvon generates program, risk-assessment and CDD documents for your review. Then Klyvon keeps working — tracking staff training and review dates, drafting SMRs, and answering the questions that come up between reviews.

Risk assessment, built to your practice

A documented ML/TF risk assessment covering your designated services, client types, and delivery channels — not a generic template with your firm's name on it.

Initial and ongoing training by role

Interactive modules assigned by staff role, with legal-sector scenarios. Completion certificates provide evidence of training and are retained under the applicable program-record retention rule.

SMR drafting when suspicion arises

Prepare an SMR draft from the transaction details entered, with legal-sector red flags and tipping-off guidance included, for review before submission.

Answers instead of pointing you at a PDF

Ask a plain question about a real client situation — a privilege claim, a settlement that doesn't add up.

Get started free →

From $299/month · free to start · cancel anytime

Related resources

What is an AML/CTF Program?

Plain English explainer

How to Submit an SMR to AUSTRAC

The 3-day and 24-hour deadlines

AML/CTF for Conveyancers

If your firm also does conveyancing

DIY vs Consultant vs Klyvon

What compliance actually costs in Australia

AUSTRAC Penalty Register

Every enforcement action since 2006

All resources

Every guide, sector explainer and tool