AML Compliance Guide
Log in Create Free Account
Deadline: 29 July 2026 — enforcement now active

Compliance officer for Lawyers — 2026 AUSTRAC Guide

If your law practice will provide a designated service from 1 July 2026, you need an AML/CTF compliance officer in place as part of getting ready for AUSTRAC regulation. For lawyers, this usually matters when the practice handles client money or assets in connection with covered transactions, not when you are giving pure legal advice only. If you do not put proper AML/CTF governance in place by the deadline, your practice risks AUSTRAC enforcement, civil penalties of up to $33.5 million per contravention, and criminal penalties for intentional breaches.

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

Your compliance officer is the person who oversees day-to-day AML/CTF compliance in the practice. They are not just a name on a form. AUSTRAC expects this person to maintain and update the firm’s ML/TF risk assessment and AML/CTF policies, make sure approvals from senior management are obtained and recorded, coordinate training, help manage suspicious matter reporting, and oversee independent evaluation of the AML/CTF program at least once every 3 years. If your firm is not a sole practice, the person must also be able to report AML/CTF issues upward to the governing body or principals.

Deadline and immediate action

If your legal practice will be newly regulated from 1 July 2026, have your compliance officer chosen and ready before you enrol with AUSTRAC, and complete enrolment by 29 July 2026. AUSTRAC enrolment is not a licence. It is a mandatory notification, and AUSTRAC Online lets you confirm the compliance officer appointment as part of your governance records.

What a law practice should do now

  • Work out whether your firm will provide a designated service. Pure legal advice is generally not the trigger for lawyers; handling money or assets in connection with transactions is the usual trigger.
  • Choose a fit and proper person as compliance officer. They need competence, judgement, honesty, integrity, and no serious disqualifying issues such as adverse regulatory findings or unmanaged conflicts.
  • Give them authority, independence and time to do the job. In a small firm this may be a principal, practice manager or senior lawyer, but they must be able to challenge risky matters.
  • Record the appointment formally with a role description, fit and proper assessment, training records, and internal approval documents.
  • Set up a reporting line so the compliance officer can take AML/CTF issues to the principal, board or partners and provide reports at least every 12 months if the practice is not run by an individual.

For lawyers, the biggest mistake is assuming the compliance officer role can wait until the AML/CTF program is finished on 31 December 2026. In practice, the officer needs to be in place earlier because they usually coordinate the risk assessment, policy drafting, customer due diligence procedures and internal reporting. Another common mistake is appointing the trust account supervisor automatically without checking whether they have enough independence, AML/CTF training and authority to stop or escalate a matter. A titled appointment with no real oversight will not help if AUSTRAC reviews your systems.

Practical tips for lawyers

  • If you act on property transfers, company or trust establishment, or client funds movement, appoint someone who understands those workflows and where risk appears in the file lifecycle.
  • Build the role into matter opening and trust account procedures so the compliance officer sees high-risk instructions early, before money moves.
  • Keep records of version history, meeting minutes, approvals, training logs and internal consultations. AUSTRAC guidance specifically points to these records as evidence of compliance.
  • Decide in advance which matters require senior manager sign-off, such as PEPs, complex ownership structures, sanctioned-party matches or unexplained source of funds concerns.

A lightweight AML platform, built exclusively for Tranche 2

Get AUSTRAC's mandates done as fast and effortless as possible.

  • Built around AUSTRAC's actual requirements
  • Single maintained compliance file
  • No compliance expertise required
  • 25 minute initial compliance setup
  • Obligations calendar & reminders
  • Instant data export
Setup: ~25 minutes Ongoing: minutes per client Price: $8 per KYC
See the product →

Frequently asked questions

Does a sole practitioner need a separate compliance officer?
Not necessarily. In a sole practice, the principal can usually perform the role if they genuinely have the skills, time and systems to do it properly. The key point is that the role must be real, documented and supported by training and records, not treated as a formality.
Can our practice manager be the compliance officer instead of a lawyer?
Yes, if that person is fit and proper and has enough authority, independence, resources and training to oversee AML/CTF compliance. In a legal practice, this often works well where the practice manager understands client onboarding, billing, trust money controls and escalation processes. They must still be able to raise concerns directly with the principals or governing body.
What if we only give legal advice and never handle client money?
Then you may not be providing a designated service at all. For lawyers, pure legal advice is generally not a designated service; the AML/CTF regime is usually triggered when the practice handles money or assets in connection with covered transactions. You should confirm your service lines carefully before deciding you do not need a compliance officer.
How much does appointing a compliance officer cost?
AUSTRAC does not charge a fee to appoint or notify a compliance officer through AUSTRAC Online, and enrolment itself is free. Your real costs are internal: staff time, training, documenting the appointment, updating procedures, and possibly external advice if your practice does higher-risk transactional work.
What happens if our compliance officer leaves after we enrol?
Replace them promptly and update your AUSTRAC enrolment details within 14 days of the change. Keep records of the resignation, new appointment, fit and proper assessment, training and handover. Do not leave the role vacant while your practice continues providing designated services.

Related guides