The AML Reckoning for Lawyers: A Five-Part Compliance Roadmap

Program 1: The AML Wake-up Call: What Tranche 2 Means for Lawyers

Lawyers are no longer flying under the AML radar. With Tranche 2 of the AML/CTF reforms coming into effect from July 2026, legal practices will soon face sweeping new compliance obligations - and the consequences of getting it wrong are significant. This opening session explains what’s changing, why lawyers are now squarely in the regulatory spotlight, and what you need to do to prepare. It covers:

• The background, drivers and objectives of the tranche 2 reforms
• The scale of financial crime and how lawyers can be used to facilitate it
• Overview of the AML/CTF Act, definitions, structure, and key concepts
• New obligations for legal practices—and how they differ from current regulations
• The implementation timeline and what legal practices should be doing now
• Resourcing, systems and expertise required to support implementation

Program 2: Are You In or Out? Designated Services and Risk Exposure for Lawyers

Think AML only applies to certain types of legal work? Think again. Your entire practice may be on the hook if even one team member delivers a designated service. This session breaks down two foundational questions every legal practice must answer: Are we captured? and What’s our risk? We’ll walk you through the messy middle—where services don’t neatly fall in or out—and show you how to assess your exposure.  It covers:

• Section 6 of the AML/CTF Act—what is and isn’t a designated service
• Grey areas and borderline scenarios, including business sales and litigation
• How to assess your practice’s AML risk based on services, client base, jurisdictions and delivery channels
• AUSTRAC’s risk-based approach: what is low, medium or high risk in practice
• Real-world examples of how legal services are used for money laundering
• Developing suspicious behaviour typologies specific to your practice

Program 3: Building Your AML Shield: Designing a Compliance Program that Actually Works

Understanding your obligations is only the beginning—now it’s time to build a compliance program that can stand up to scrutiny. Whether you’re a sole practitioner or managing a national firm, your AML/CTF program must be tailored, risk-based, and robust enough to catch suspicious activity before the regulator does. This hands-on session shows you how to move from checklists to a fully functioning compliance framework. It covers:

• Core components of a compliant AML/CTF program under Section 1A
• Aligning policies with your risk profile—what to include and how to draft
• Creating effective internal reporting lines and escalation protocols
• Designing typologies and identifying ‘suspicious’ transactions in context
• The roles required under the Act—who’s responsible for what
• When and how to bring in external support and vendors—and what to keep in-house

Program 4: Know Your Client, Protect Your Practice: CDD and Record Keeping Under the AML Regime

The AML/CTF reforms demand far more than just a photocopy of a driver’s licence. Lawyers will be expected to dig deeper, verify more, and keep detailed records that prove they’ve done so—without compromising client relationships or breaching confidentiality. This session takes a practical, no-nonsense look at how to embed customer due diligence (CDD) into the life of a legal practice. Learn how to ask the right questions, spot red flags, and comply with new verification and storage obligations—while still maintaining the trust of your clients. It covers:

•  What CDD really involves—initial checks, ongoing monitoring, and when enhanced due diligence kicks in
• How to handle complex scenarios like foreign clients, politically exposed persons (PEPs), and high-risk jurisdictions
• Techniques for verifying identity, beneficial ownership and source of funds—without alienating clients
• How to adjust your record-keeping systems to satisfy the new regime while respecting privacy and privilege
•  What the Rules and Guidance say about verification standards and exemptions
• Practical strategies for extracting sensitive information professionally and ethically
• How to separate AML records from the matter file to ensure confidentiality and audit readiness

Program 5:  Under the Microscope: AUSTRAC, Enforcement and Independent Reviews

The AML reforms don’t just end with a compliance manual—they bring your entire practice under regulatory oversight. With AUSTRAC taking the lead on enforcement, law firms must be ready for audits, reviews, and uncomfortable questions if things go wrong. This final session arms you with the knowledge and practical tools to stay on the front foot with the regulator. From managing audits to navigating grey areas like tipping off and privilege, it’s about protecting your practice, your clients—and your professional reputation. It covers:

• How AUSTRAC fits into the AML enforcement ecosystem—and how lawyers might come to its attention
• The AML reporting chain: how your data connects to a bigger picture of financial crime
• Understanding ‘tipping off’ risks and how to reconcile your AML duties with client confidentiality and privilege
• When independent reviews are required, what they involve, and how to prepare for them
• What to expect during audits or investigations—and how to handle self-reporting and regulator notices
• The evolving ethical landscape: law society guidance, professional standards and emerging grey zones