AML Compliance Guide
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Staff training for Lawyers — 2026 AUSTRAC Guide

If your law practice provides a designated service from 1 July 2026, you must train the people in your firm who deal with clients, client money, onboarding, transaction handling, or AML/CTF decisions. For lawyers, this usually matters where the practice handles money or assets in connection with transactions, not where it gives pure legal advice only. If you do not train relevant staff properly and keep records, AUSTRAC can treat that as a compliance failure, with civil penalties 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

For a law practice, staff training is not a one-off seminar. Your training must match each person’s role in the firm and the actual money laundering and terrorism financing risks in your matters. That means a partner approving higher-risk property or corporate work needs different training from a receptionist, trust account clerk, paralegal, conveyancing assistant, or practice manager. Training must be documented, repeated when your AML/CTF program is updated, and understandable to the person receiving it. AUSTRAC also expects general awareness training at onboarding for personnel not in AML/CTF-relevant roles.

What your law practice needs to do

  • Work out which roles in the firm need AML/CTF training: partners, employed solicitors, paralegals, conveyancers, trust account staff, client onboarding staff, finance staff handling client funds, and anyone reviewing unusual transactions.
  • Build training into your AML/CTF program and tailor it to your legal services, such as property settlements, managing client money, company or trust setup work, or acting in transactions involving assets.
  • Train relevant staff before they perform AML/CTF functions, then refresh training on the required cycle and whenever laws, risks, procedures, or AUSTRAC guidance change.
  • Keep a training register showing who was trained, on what topics, how it was delivered, the version of the material used, and any assessment or follow-up action.

Training frequency AUSTRAC expects

AML/CTF compliance officers and senior management: every 6–12 months. Customer-facing personnel: every 12 months. Staff responsible for onboarding, transaction monitoring, or enhanced CDD: every 12 months. Third-party vendors: when onboarded and when the contract is renewed or changed. Other personnel not in AML/CTF-relevant roles: at onboarding for general awareness.

For lawyers, good training is practical and matter-based. Cover when legal work is and is not a designated service, because many firms get this wrong. Pure legal advice is generally not a designated service, but handling money or assets in connection with a transaction can trigger obligations. Your training should show staff how to verify individuals, companies and trusts, how to identify beneficial owners with 25% or more ownership or effective control, when to apply enhanced due diligence to PEPs or high-risk matters, how to screen against DFAT and UN sanctions lists, and how to escalate a suspicious matter without tipping off the client.

Common mistakes in law firms

  • Training all lawyers the same way and ignoring role differences between fee earners, trust account staff, and support staff.
  • Assuming ethics or trust accounting CPD already covers AML/CTF training. It does not unless it is tailored to your AML/CTF program and designated services.
  • Telling staff that every client needs an SMR if documents seem incomplete. The test is reasonable grounds to suspect, and staff need clear internal escalation steps.
  • Using generic outsourced training without adapting it to your practice areas, matter types, and internal procedures.
  • Failing to retrain staff after your AML/CTF program changes or after a control failure, near miss, or AUSTRAC update.

Use short role-based modules rather than one long session. A small firm can combine online learning, file review, partner briefings, and trust account workflow training, but the content still needs to align with your own AML/CTF program. If someone misses training or does not understand it, give targeted follow-up or remedial training, document the result, and reassess their competence. If they still cannot perform the role safely, reassign the AML/CTF-related functions. Keep records for 7 years after the relationship ends, and keep training materials, attendance logs, calendars, assessment results, and version history so you can show AUSTRAC what the firm actually did.

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Frequently asked questions

Do all staff in my law firm need AML/CTF training?
Not at the same level. Staff who deal with clients, onboarding, client money, settlements, trust structures, company setup work, sanctions screening, or suspicious matter escalation need role-specific training. Staff outside AML/CTF-relevant roles should still receive general awareness training at onboarding.
If my firm only gives legal advice and never handles client money or assets, do I still need this training?
If your practice does not provide a designated service, the AML/CTF regime does not apply to that work. For lawyers, pure legal advice is generally not a designated service. You need to assess your actual services carefully, because obligations can be triggered when the firm handles money or assets in connection with transactions.
Can I use a generic online AML course for my solicitors and support staff?
You can outsource training, including online modules, but you remain responsible for making sure it is tailored, appropriate and understandable for your staff. Generic training is not enough on its own if it does not cover your practice areas, your AML/CTF program, and the roles of your personnel. Most firms will need to add internal content about their matter types, trust account processes, and escalation pathways.
How much will this usually cost a small law firm?
There is no set AUSTRAC fee for staff training itself. Cost depends on whether you prepare training internally, use an external provider, or combine both, and how many roles need tailored content. Small firms often keep costs down by using a short core module for everyone affected, then adding targeted sessions for partners, onboarding staff, and trust account personnel.
What records should I keep to prove the training happened?
Keep training schedules, attendance records, training materials, version history, assessment results, and notes of any remedial follow-up. Your register should show who completed training, their role, what was covered, how it was delivered, and when they need refresher training. Also keep evidence of action taken where someone missed training or was not yet competent.

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