AML Compliance Guide
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Deadline: 29 July 2026 — enforcement now active

AUSTRAC enrolment for Lawyers — 2026 AUSTRAC Guide

If your law practice will provide a designated service from 1 July 2026, you must enrol with AUSTRAC. For lawyers, this is not triggered by every matter you handle — it is generally triggered when your practice handles money or assets in connection with certain transactions, not when you give pure legal advice alone. If you do not enrol on time, you risk serious enforcement action, including civil penalties of up to $33.5 million per contravention, and criminal penalties can apply for intentional contraventions.

Your AML/CTF obligations

  1. 1. AUSTRAC enrolment
  2. 2. Compliance officer
  3. 3. ML/TF risk assessment
  4. 4. AML/CTF program
  5. 5. Customer due diligence
  6. 6. Sanctions screening
  7. 7. Suspicious matter reporting
  8. 8. Record keeping (7 years)
  9. 9. Staff training

Enrolment is the first legal step for a law firm, incorporated legal practice, sole practitioner or other legal business that becomes a reporting entity. It is a notification to AUSTRAC that your practice provides a designated service under the AML/CTF Act. It is not a licence and it does not mean AUSTRAC has approved your firm. Once you are enrolled, your practice is expected to meet the rest of its AML/CTF obligations as they come due, including risk assessment, an AML/CTF program, customer due diligence, sanctions screening, reporting, record keeping and staff training.

Hard deadline for existing legal practices

If your practice will be providing a designated service from 1 July 2026, you must enrol with AUSTRAC by 29 July 2026. If your legal business starts after 1 July 2026, you must enrol within 28 days of first providing the designated service. Enrolment is done through AUSTRAC Online at austrac.gov.au and there is no fee.

What a lawyer should do now

  • Work out whether your practice actually provides a designated service. Do not assume every legal service is captured. Pure legal advice is generally not designated; handling client money or assets in connection with transactions is the usual trigger.
  • Map the matters and work types that may be captured, such as property transactions, managing client money for a transaction, or setting up entities and structures where the service falls within Schedule 1.
  • Decide which legal entity is enrolling — for example, the incorporated legal practice, partnership or sole trader that provides the service.
  • Gather the details AUSTRAC asks for through AUSTRAC Online, including business structure, contact details, services provided and key personnel.
  • Submit the enrolment through AUSTRAC Online by 29 July 2026, then keep the enrolment details accurate. If details change, update them within 14 days.

The most common mistake for lawyers is treating enrolment as something only trust account practices need to do, or assuming a practising certificate or state-based legal registration covers it. It does not. AML/CTF obligations are federal and sit alongside your legal profession rules. Another common mistake is enrolling too late because the practice is still deciding whether it will offer captured services after 1 July 2026. If there is a real prospect that your firm will provide a designated service from commencement, treat enrolment as urgent and settle the question early.

Practical enrolment tips for legal practices

  • Nominate one person to own the enrolment process, usually the principal, practice manager or the person who will become the AML/CTF compliance officer.
  • Review your matter types, costs agreements, trust account workflows and client intake forms together. That is often where designated services are easiest to identify.
  • If your firm has separate entities for legal services, conveyancing, or property-related work, check which entity actually contracts with the client and receives the fee.
  • Keep a file note recording why you concluded the practice is or is not providing a designated service. That helps if AUSTRAC or your insurer later asks how you reached the decision.
  • Do not wait for your AML/CTF program to be finished before enrolling. Enrolment comes first; the program must be finalised by 31 December 2026.

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Frequently asked questions

Do I need to enrol if my firm only gives legal advice and never handles client money?
Not usually. Pure legal advice is generally not a designated service for lawyers. The trigger is usually that your practice handles money or assets in connection with certain transactions or provides another legal service that falls within Schedule 1 of the AML/CTF Act, so you need to assess your actual services carefully.
Our firm does a small amount of conveyancing and property work. Do we still need to enrol?
Yes, if that work includes a designated service. The size of the practice or the fact that it is only a small part of your revenue does not remove the obligation. If the legal entity provides a designated service from 1 July 2026, enrolment is mandatory.
Is AUSTRAC enrolment the same as getting approved or licensed by AUSTRAC?
No. Enrolment is not a licence and it is not an approval process. It is a mandatory notification to AUSTRAC that your legal practice is a reporting entity because it provides a designated service.
How much does enrolment cost and where do we do it?
Enrolment is free. You complete it through AUSTRAC Online on the AUSTRAC website. AUSTRAC opened the new enrolment form for newly regulated businesses from 31 March 2026, so firms can prepare before obligations start on 1 July 2026.
What if we are not sure whether the designated service is provided by the partnership, the incorporated legal practice, or a related entity?
You need to identify the legal entity that actually provides the service to the client. Look at the retainer, invoice, trust money handling, and which entity enters the transaction-related engagement. If different entities in the group provide different services, more than one entity may need separate consideration for enrolment.

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