From 1 July 2026, some Australian lawyers, conveyancers, accountants, real estate professionals and other professional service providers are expected to become subject to expanded anti-money laundering and counter-terrorism financing obligations.

Yes, it is a mouthful. No, it is not something invented by lawyers to make paperwork more exciting.

These changes are part of Australia’s broader reforms to its anti-money laundering and counter-terrorism financing regime, commonly called AML/CTF. The aim is to make it harder for organised crime and professional money laundering networks to use legitimate businesses and professional services to move, hide or disguise money.

In other words: the Government is trying to stop criminals from using respectable-looking transactions as a washing machine for dirty money.

Why Are These Changes Happening?

AUSTRAC has explained that there are gaps in Australia’s financial system that can be exploited by organised crime. The reforms are intended to close those gaps and bring Australia more closely into line with international standards set by the Financial Action Task Force, the global financial crime watchdog.

Australia has also been under pressure internationally because many comparable countries already regulate professional “gatekeepers” such as lawyers, accountants, conveyancers and real estate professionals in relation to AML/CTF risk.

The reforms are not directed at ordinary clients doing ordinary things. They are directed at reducing the risk that professional services are misused for criminal purposes.

What Types of Legal Work May Be Affected?

The new regime does not simply regulate a law firm because it is a law firm. It focuses on whether the firm is providing particular types of services, called designated services.

For lawyers and other professional service providers, these may include certain services involving:

• buying, selling or transferring real estate;
• buying, selling or transferring companies, trusts or other legal arrangements;
• receiving, holding, controlling or managing money or property as part of a transaction;
• assisting with equity or debt financing for a company or legal arrangement;
• creating or restructuring companies, trusts or other legal arrangements;
• acting, or arranging for someone to act, in certain roles for companies or legal arrangements; and
• providing a registered office or principal place of business address for certain entities.

Not every legal matter will be caught. A straightforward advice matter may be treated differently from a conveyancing transaction, estate asset transfer, trust establishment, company restructure or transaction involving client money.

The difficult part, and the part causing some understandable industry concern is that legal matters can evolve. A matter that begins as general advice can later become a transaction. A simple enquiry can turn into a property transfer. A “quick question” can, as lawyers everywhere know, become a small novel with annexures.

What Does This Mean for Clients?

For many clients, the most noticeable change will be that law firms may need to ask for more information before commencing work, continuing work, receiving money, paying money or completing a transaction.

This may include:

• proof of identity;
• verification of address;
• information about the person giving instructions;
• information about companies, trusts, estates or other entities involved;
• details of directors, trustees, beneficiaries, shareholders or beneficial owners;
• information about the source of funds;
• information about the source of wealth;
• the purpose of a transaction;
• details of proposed payments or recipients; and
• additional supporting documents.

In short: if a lawyer asks why money is coming in, where it came from, who controls an entity, or why funds are being paid somewhere, it is not because the lawyer has developed a sudden passion for detective work. It may be because the law requires the lawyer to ask.

“But I’ve Been a Client for Years”

Long-standing clients may still be asked for updated identification or further information.

This can feel odd, especially where a client has dealt with the same firm for years. However, AML/CTF obligations are not based only on whether a lawyer personally knows a client. They require formal processes, records and risk assessments.

So yes, even familiar clients may be asked to provide documents. It is not personal. It is compliance.

Think of it as the legal version of airport security: inconvenient, occasionally repetitive, but not optional.

Will This Cause Delays?

Possibly.

If a matter is affected by AML/CTF obligations, certain checks may need to be completed before work can commence or continue, before money can be received into trust, before funds can be disbursed, or before a transaction can be completed.

Delays may occur if:

•  identification documents are not provided promptly;
• information about the source of funds is incomplete;
• an entity structure is complex;
• trust, company or estate documents are missing;
• there are multiple parties involved;
• payment details need to be verified; or
• additional risk checks are required.

Clients can help reduce delays by providing requested information as early as possible.

Will There Be Additional Costs?

In some matters, yes.

AML/CTF compliance may involve additional administrative work and third-party verification costs, including:

• electronic identity verification;
• company or trust searches;
• beneficial ownership checks;
• sanctions screening;
• politically exposed person checks;
• source of funds enquiries;
• source of wealth enquiries;
• trust accounting compliance checks; and
• payment verification.

Law firms may charge administrative fees for this work and may pass on third-party verification costs as disbursements.

This is not because lawyers have discovered a thrilling new revenue stream in photocopies of passports. It is because compliance takes time, systems and record-keeping.

Trust Money: Please Do Not Send Funds Without Instructions

One practical change clients should expect is stricter control around money being paid into trust accounts.

Clients should not transfer money to a law firm’s trust account unless the firm has confirmed that payment may be made and has provided payment requirements.

Before receiving or paying out money, a law firm may need to complete identification, AML/CTF, source of funds, authority and payment verification checks.

If money is sent without prior approval, the firm may not be able to deal with it immediately.

Are Lawyers Happy About This?

The legal profession supports the objective of preventing money laundering and terrorism financing. These are serious issues that cause real harm.

However, there has been concern about the timing, complexity and uncertainty of the reforms, particularly for small firms. The Law Council of Australia has reportedly called for more time or, at minimum, a transitional compliance period focused on education and assistance rather than enforcement.

The concern is not with the goal. The concern is with making sure firms can clearly identify when obligations apply and implement systems properly.

In practical terms, law firms are preparing for a significant compliance change while also waiting for further clarity in some areas. It is a little like being told to pack for a holiday without being told whether the destination is the beach, the snow or a parliamentary inquiry.

What Should Clients Do Now?

Clients can prepare by expecting that, from 1 July 2026, law firms may ask for more information at the start of a matter and at key stages during a transaction.

Helpful steps include:

• having current identification documents available;
• keeping records showing where funds have come from;
• keeping company, trust or estate documents organised;
• responding promptly to requests for information;
• not transferring money until payment instructions are confirmed; and
• allowing extra time for compliance checks in transaction timelines.

The Bottom Line

The AML/CTF reforms are designed to make Australia’s financial system harder for criminals to exploit. For clients, the main practical effect is likely to be more upfront questions, more identity checks, more verification and possibly some additional costs or delays.

It may feel like extra paperwork. It is.

But it is paperwork with a purpose.

From 1 July 2026, if Burns & Tinney asks for identification, source of funds information or additional documents, it is not because anyone is suspected of wrongdoing. It is because legal service providers may be required by law to complete those checks before certain work, trust money dealings or transactions can proceed.

Compliance may not be glamorous, but then again, neither is money laundering.

And that is rather the point.

Disclaimer

This article is general information only and is current as at 12 June 2026. AML/CTF obligations may depend on the type of service being provided, the parties involved and the circumstances of the matter. Further regulatory guidance and legislative developments may affect how the regime applies.

Written by Kaylee Karam, solicitor