Our approach to
Anti Money Laundering / Counter Terrorism Financing
From 1 July 2026, amendments to federal Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws will require firms like ours to complete additional identity checks before we can provide certain services.
New reforms introduced by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) have extended obligations that have applied to banks, casinos and financial institutions for years to professional services, including lawyers and conveyancers that provide certain “designated services“.
The purpose is to make it harder for criminal groups to use legitimate professionals to launder the proceeds of crime or finance terrorism.
This page contains information on:
- What is AML/CTF and how will these changes affect me?
- Which of our services are “designated services”
- What documents you may be asked to provide
- What questions we may ask, including about politically exposed persons
- How the verification process works
- How we protect your privacy and your information
What is AML/CTF and how will these changes affect me?
From 1 July 2026, where our work for you involves a designated service, the law requires us to first:
- collect information about you and verify your identity;
- where you instruct us through a company, trust or other structure, identify the individuals who ultimately own or control it;
- understand the purpose and nature of the matter or transaction;
- assess and document any money laundering or terrorism financing risk; and
- keep proper records of the checks we’ve carried out and the decisions we’ve made.
Important: We are legally required to undertake these activities, regardless of how well we may already know you.
Which services are 'designated services'
AML requirements will now apply whenever we are providing a ‘designated service’ for your matter. Designated services typically include where we assist with:
- Buying, selling or transferring real estate.
- Buying, selling or transferring a company or legal arrangement.
- Managing client funds.
- Setting up or restructuring trusts and companies.
- Certain financial and transactional advisory services.
At the start of each matter, we will ascertain if a designated service is required and, if so, what level of checks we will need to undertake.
What documents might I be asked to produce?
The amount of documentation you will be required to provide will depend the level of risk involved. Most clients will be asked to provide some combination of:
- Photo identification – for example, a passport or driver’s licence.
- Proof of address – for example, a recent utility bill or bank statement.
- Company, trust or SMSF documents – where you’re instructing us through a structure.
- Ownership and control information – for more complex entities, so we can identify who ultimately owns or controls them.
- Source of funds information – for higher-risk matters only.
If you’re acting through a company, trust or other structure, we’ll need to identify and verify the individuals behind it, not just the entity itself.
Note: you will provide these documents via a secure platform we have engaged solely for this verification process.
What questions might I be asked?
As part of these checks, we may ask for some additional information to confirm your identity, understand who we’re acting for, and decide whether any further due diligence is needed. This can include asking whether you, your representative, or your close family members or business associates are, or have ever been, a politically exposed person (PEP).
A PEP is broadly someone who holds, or has held, a prominent public position in Australia, overseas, or within an international organisation – for example, senior politicians, judges, ambassadors, senior military officers, senior public servants, or senior officers of state-owned entities. Being a PEP is not a problem in itself; it simply means we may need to carry out some additional checks.
The main categories are:
A domestic PEP is an individual who is in or has been in the following position:
- Members of the Commonwealth, State or Territory Parliament
- Governor-General
- State governors and Territory Administrators
- High Court, Federal Court and State/Territory Supreme Court judges
- Heads of government departments and agencies
- Senior Defence Force officers; and
- Senior officers of state-owned companies.
A foreign PEP is an individual who holds or has held a prominent office or position or public function in or for the legislature, executive or judiciary of a foreign country. This includes an individual who holds or has held any of the following offices or positions:
- head of state or head of government
- member of the executive council of government
- member of a legislature
- minister, deputy minister or equivalent office or position
- judge of a supreme court, constitutional court or other court of general jurisdiction or last resort
- ambassador, high commissioner or charge d’affaires
- high ranking military officer
- head or board member of a government body
- head or board member of a state‑owned company or a state‑owned bank
- member of a governing body of a political party represented in a legislature.
A foreign PEP is also a family member of an individual listed above or an individual who is known (based on information that’s public or readily available) to have:
- joint beneficial ownership of a body corporate or legal arrangement with an individual listed above
- sole beneficial ownership of a body corporate or legal arrangement on behalf or for the benefit of an individual listed above
- any other close business relations with an individual listed above.
An international organisation politically exposed person (PEP) is someone who currently holds, or has previously held, a prominent public role, position, or office within a public international organisation. This includes individuals such as the head, deputy head, or members of the governing board of organisations like those within the United Nations.
The term also extends to:
- family members of such individuals; and
- individuals who are known, based on publicly available or readily accessible information, to have certain connections with them.
These connections may include:
- jointly owning or benefiting from a company or legal arrangement with the individual;
- holding sole beneficial ownership of a company or legal arrangement on behalf of, or for the benefit of, the individual; or
- maintaining any other close business relationship with the individual.
A family member includes:
- a spouse, de facto partner, or equivalent under any applicable law of a foreign country, of the individual
- a child of the individual
- a spouse or de facto partner, or equivalent under any applicable law of a foreign country, of a child of the individual
- a parent of the individual.
How will the process work?
Our process is designed to be straightforward and secure. How long it takes depends on the nature of the matter, but most clients complete it quickly once they’ve provided their documents. It begins after you’ve contacted us about a matter.
- Scope the matter
We will gather enough information to work out whether your matter involves a designated service that requires AML/CTF checks. - Engagement documents
You’ll receive our costs agreement, terms of engagement, and a description of the work we’ll be doing. - Agree to commence engagement
If you accept our scope, terms and costs and signed our agreement, we will begin the verification process for any designated service. - Share your details
You’ll be invited to provide your identity information and any relevant documents through our secure verification platform. - Verify your information
The platform guides you through providing your identity and ownership details safely. - Clarify any matters
If we need any further documents or explanations, we’ll get in touch promptly. - Complete the assessment
Once we receive the report, we will review the verification results and finalise our risk assessment for the matter. - We begin work
Once the checks are complete and we’re satisfied, we can start work on your matter.
How we protect your information
We take the privacy and security of your information seriously. Anything you provide is handled in accordance with:
- Australian privacy law;
- our professional and confidentiality obligations as a law practice; and
- our AML/CTF regulatory obligations.
We use your information only for identity verification, compliance and onboarding. We do not use it for marketing, and we never sell or trade client information.
We make use of a third-party company called InfoTrack to assist us in obtaining searches and completing enquiries required for AML/CTF compliance. InfoTrack stores its data in Australia and uses a robust platform with multiple layers of intrusion detection and prevention systems, and is certified on ISO27001:2022 (Information Security Management System) and ISO9001:27001 (Quality Management System).
If you have any questions about these changes, or about what we need from you and why, please get in touch with us.
