What Australian law firms need to know about the AML compliance reforms

Significant changes to Australia’s Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) laws are on the way. These reforms, driven by updates to the AML/CTF Act, will for the first time apply to all law firms operating in Australia and bring them under AUSTRAC regulation.

Key milestones are approaching fast: enrolment begins 31 March 2026, and full obligations take effect 1 July 2026. Many firms are asking:

  • What exactly is changing?
  • What do we need to do, and by when?
  • How will this affect our day-to-day practice?
  • How can Smokeball help?

This guide brings together the key facts, timelines and obligations, and points you to trusted resources so you can start preparing with confidence.

The AML compliance timeline

Key dates to know

31 March 2026

Law firms must enrol with AUSTRAC and begin implementing AML/CTF compliance steps.

1 July 2026

Full AML/CTF obligations apply; Tranche 2 regulation formally begins.

The timeline below outlines AUSTRAC’s planned rollout of the new AML/CTF framework, from the release of new rules and guidance through to full Tranche 2 commencement. These milestones are important for law firms planning their AML compliance activities and system readiness. Throughout this timeline, AUSTRAC will release guidance and supporting materials to help newly regulated entities prepare.

AML FAQs

Why are Australia’s anti-money laundering and counter-terrorism financing laws changing?

On 29 November 2024, the Australian Parliament passed the AML/CTF Amendment Bill 2024, introducing major reforms to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML Act).

The goal of these reforms is simple: close gaps in Australia’s financial system that can be exploited by organised crime and professional money laundering networks. The updated regime also ensures Australia meets international standards set by the Financial Action Task Force (FATF) - the global standard-setter for combating financial crime.

A major outcome of the reforms is the introduction of ‘tranche 2’ entities - new industries that are recognised as high-risk and will now be regulated by AUSTRAC.

From 1 July 2026, this includes:

  • Lawyers and law firms
  • Conveyancers
  • Accountants
  • Real estate professionals
  • Trust and company service providers
  • Dealers in precious stones, metals and products

For law firms, this marks a significant regulatory shift.

What law firms can do right now to prepare for AML/CTF obligations?

Firms can take practical steps today to stay ahead of AML/CTF compliance. With AUSTRAC enrolment starting 31 March 2026 and full obligations from 1 July 2026, there is still time to prepare without feeling overwhelmed.

1. Confirm if the rules apply to your firm

2. Assign responsibility

  • Nominate someone within your firm to oversee AML compliance

3. Review your client processes

  • Check how you verify client identity and keep records
  • Note any areas that could be documented or streamlined

4. Align your technology

  • Make sure your practice management system can capture client information and track matters efficiently
  • Identify simple workflow improvements that support compliance

5. Keep learning and stay informed

  • Watch webinars, read AUSTRAC updates, and review sector-specific guidance as it becomes available
  • Watch webinars, read AML product updates from Smokeball
  • Start mapping compliance steps into your daily practice

6. Complete upcoming key milestones

  • 31 March 2026: enrol with AUSTRAC
  • 1 July 2026: full AML/CTF obligations apply

Taking small, practical steps now will help your firm be ready without stress when full compliance begins.

What will law firms be required to do under the AML Act?

At a high level, the new AML/CTF obligations mean law firms will need to:

1. Establish an AML/CTF compliance program

Firms must:

  • Develop and maintain an AML/CTF compliance program
  • Nominate a compliance officer responsible for oversight

2. Conduct customer due diligence (CDD)

This includes:

  • Verifying client identity
  • Understanding the nature and purpose of the legal service
  • Assessing and managing money laundering and terrorism financing risk

3. Monitor certain transactions

Law firms will need systems and processes to:

  • Monitor international monetary transfers
  • Track cash transactions over $10,000

4. Report and keep records

Firms must:

  • Report suspicious matters to AUSTRAC
  • Maintain clear audit trails to evidence AML/CTF compliance
  • Keep records in line with regulatory requirements

How Smokeball is preparing to support AML/CTF compliance

While AML/CTF compliance is ultimately a firm responsibility, technology plays a critical role in supporting your compliance journey by making AML information easy to manage and track.

We’re currently working on new product enhancements designed to support law firms as they prepare for AML/CTF obligations, including:

  • Improvements to our InfoTrack integration to better support identity verification and automate AML status updates
  • Enhancements to contact cards, making it easier to capture, edit and maintain all the relevant client information for AML compliance
  • Ongoing refinements to help firms track activity, maintain records, and evidence compliance within Smokeball

We’ll be sharing more detail on these enhancements closer to release.

Where can I find official guidance and updates?

AUSTRAC is the source of truth for AML compliance and anti-money laundering regulation in Australia. We strongly recommend law firms review and bookmark the following resources:

Resources to support you

If you prefer to learn through live sessions and practical walkthroughs, we’ve listed a collection of events, webinars, and content designed to help law firms prepare for AML compliance and Tranche 2 regulation.

Ready-Set-Go AML/CTF Roadshow

Ready-Set-Go AML/CTF Roadshow is an upcoming event roadshow hosted by our partner InfoTrack, offering practical guidance and technology insights to help businesses prepare for Tranche 2 AML/CTF compliance. The roadshow will be visiting 26 locations along and around the East Coast of Australia throughout March.

Each session focuses on what firms need to do now, how to get ready, and how technology can support compliance under the AML Act.

Learn more and register here.

Watch our video on the Tranche 2 AML reform

To help unpack what these changes mean in practice, Hunter Steele, Smokeball’s CEO and John Ahern, InfoTrack’s CEO, recently hosted a discussion on Tranche 2 AML reform and its impact on law firms and what firms need to do to prepare.

Watch the video here.

Watch the webinar

For a deeper, practical walkthrough of how law firms can prepare, you can also watch our webinar: From Risk to Readiness: Preparing for Tranche 2 AML Regulation

In this session, Kristy, Executive Head of Product and Client Experience at InfoTrack, discusses the upcoming AML/CTF reforms and outlines a three-stage compliance process to help law firms move from awareness to readiness.

Watch the webinar recording here.

Smokeball will continue to keep you updated as the regulatory landscape evolves - and as we roll out new features designed to make compliance simpler within your existing workflows. We’ll share more soon.

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