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AML compliance lawyers Australia 2026

AML Compliance for Lawyers and Law Firms: Your Tranche 2 Obligations

Law firms become exposed when they move beyond advice and help execute transactions, hold funds, or create structures.

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Are you affected?

If your law firm handles settlement funds, forms companies or trusts, assists with financing, or holds client money beyond professional fees, you may need an AML/CTF program before 1 July 2026.

Your obligations

  1. Enrol with AUSTRAC now that enrolment is open
  2. Build an AML/CTF program tailored to your services
  3. Implement customer due diligence procedures
  4. Train staff on red flags and process
  5. Maintain records and reporting readiness
Henderson & Cole Legal Solicitors · ABN 98 765 432 109 · Sydney NSW AML/CTF Risk Assessment — Prepared by Assemble Compliance ASSEMBLE ML/TF RISK ASSESSMENT — MATTER: CHEN FAMILY TRUST — HC-2026-0089 SECTION 1 — MATTER DETAILS CLIENT NAME David & Linda Chen MATTER TYPE Family trust establishment MATTER VALUE $2.1M (property transfer) DESIGNATED SERVICE(S) Trust formation + real property transfer into trust structure SECTION 2 — ML/TF RISK FACTOR ASSESSMENT RISK FACTOR ASSESSMENT RISK RATING Customer type Australian residents, married couple LOW Service/product type Trust formation + property transfer HIGH Delivery channel In-person meetings, email correspondence LOW Foreign jurisdiction Linda born overseas (Singapore), now citizen MEDIUM PEP / Sanctions status Not a PEP. No sanctions match. LOW Transaction value $2.1M residential property into discretionary trust HIGH Source of funds Property equity (existing home, no mortgage) MEDIUM OVERALL ML/TF RISK RATING: MEDIUM Enhanced CDD required SECTION 3 — ASSESSOR NOTES Enhanced CDD applied due to trust formation + high-value property transfer. Source of funds evidence obtained. Assessed by: James Henderson, Principal Date: 22 April 2026 SAMPLE by Assemble Compliance — assemblecompliance.com.au
Sample legal matter risk assessment included in the program build.

In scope

  • Conveyancing and settlement funds
  • Setting up trusts or companies for clients
  • Acting as trustee or holding funds in trust
  • Assisting with equity or debt financing
  • Creating or operating a body corporate
  • Providing registered office services

Out of scope

  • Litigation advice and court appearances
  • Barristers on instructions from solicitors
  • Pure legal advice not advancing a transaction
  • Trust accounts for professional fees only
  • Advocacy and courtroom work
  • Standalone document review

The risk of waiting

Waiting compresses everything: scope assessment, drafting, review, training, enrolment admin, and implementation. That is how firms end up rushing the most important part.

How we help

We package the work into a fixed-scope build so your team is not trying to interpret guidance, draft procedures, and pressure-test scope at the same time.

Do law firms need an AML program?

Firms involved in designated transactional services should expect to enrol with AUSTRAC and document a working AML/CTF program.

Does legal advice alone trigger the rules?

Pure advice is different from helping complete a designated transaction. Transaction support and fund handling are where the obligations become real.

What if our firm mostly does conveyancing?

Conveyancing is one of the clearest Tranche 2 exposure areas and should be treated as high priority.

Primary action

Build My Compliance Program

Start with the short form. We review the details, check likely scope, and respond personally with the right next step for your lawyers firm.

What happens after you submit?

  1. We review your firm, services, and likely AML/CTF scope.
  2. We identify the fastest path to a compliant program and likely package fit.
  3. You get a personal reply from Assemble Compliance with next steps.

No obligation. No hard sell. We review your firm first and reply personally.


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