AML/CTF
AML/CTF For Accountants, Lawyers And Conveyancers: What Changes From 1 July 2026
A practical 2026 AML/CTF guide for Australian accountants, lawyers and conveyancers covering designated services, client money, property transactions, company and trust services, CDD and evidence.
10 min read | 2026-08-22
Professional services need a matter-based view
For accountants, lawyers and conveyancers, AML/CTF exposure often depends on the type of client matter or transaction being handled. A firm may provide many ordinary services, but only some activities may be captured as designated services.
That is why a matter-based assessment is more useful than a broad firm-wide assumption. The business should identify whether it assists real estate transactions, handles client money or property, creates or restructures companies or trusts, arranges financing, or provides nominee, office-holder or address services.
- Map services by matter type, not just by practice area.
- Identify client money, property or asset handling.
- Check company, trust and legal arrangement services.
- Check real estate transaction involvement.
- Record where services are not captured and why.
Common professional-service triggers
The highest-risk professional-service scenarios usually involve helping clients move, control, create or restructure assets, entities or legal arrangements. These activities can provide opportunities for criminals to disguise ownership, move funds or place illicit value into legitimate structures.
A firm should not wait until a regulator or adviser asks for the answer. It should keep an internal register of services and matter types that may trigger AML/CTF controls.
- Assisting with sale, purchase or transfer of real estate.
- Creating, selling, transferring or restructuring companies, trusts or legal arrangements.
- Receiving, holding, controlling or managing client money, property or assets for a transaction.
- Arranging equity or debt financing for a body corporate or legal arrangement.
- Acting as, or arranging another person to act as, director, secretary, trustee or nominee shareholder.
- Providing registered office, principal place of business or correspondence address services.
CDD and beneficial ownership controls
Professional services should prepare customer due diligence processes that fit how their matters actually work. That includes client identification, beneficial ownership, control, source-of-funds prompts, matter-risk assessment and escalation when information is incomplete or suspicious.
For firms, the challenge is often consistency. One partner, accountant or conveyancer may collect excellent records while another keeps key information in email. AML/CTF readiness requires a controlled and repeatable process.
- Client identification and verification procedure.
- Beneficial ownership checks for companies, trusts and complex structures.
- Matter-risk assessment by service, client type, jurisdiction and transaction pattern.
- Enhanced due diligence triggers for high-risk matters.
- Escalation pathway for suspicious matter consideration.
- File review and quality assurance records.
Evidence firms should be ready to produce
A professional-services AML/CTF evidence pack should show both the firm's framework and a sample of how it is applied. Policies and templates matter, but regulators, reviewers and management also need to see real implementation through files, registers, training and review notes.
The most defensible position is an evidence trail that links each obligation to a current record, owner and review date.
- AML/CTF program and risk assessment.
- Designated service register by matter/service type.
- CDD and beneficial ownership records.
- Client money or trust account control evidence where relevant.
- Training register for partners, staff and contractors.
- Suspicious matter escalation records.
- Independent evaluation, internal review or remediation records.
A practical first step
The fastest useful first step is to complete a designated-service assessment before building a full program. That prevents the business from overbuilding controls in the wrong places or missing the matter types that matter most.
Complynce supports that workflow through the free AML/CTF checker and a portal structure for scope records, obligations, evidence, actions and reports.
- Use the checker to identify likely trigger areas.
- Create a professional matter/service register.
- Assign ownership for program, CDD, training and reporting controls.
- Link evidence to each applicable obligation.
- Review scope whenever the firm adds new services.
Next step
Check whether AML/CTF applies, then organise the evidence trail.
Use the free checker first. If AML/CTF applies, request the free Complynce AML/CTF Portal to manage obligations, records, evidence, actions and reports.