AML/CTF Rules 2025: Enrolment for law firms

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Understanding AML/CTF Rules 2025 Part 3: Enrolment, and what it means for the law sector

From July 2026, Australian law firms that provide designated services under the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act will face new compliance obligations for the first time.

A key requirement is enrolment with AUSTRAC. For many law firms. especially partnerships with complex structures, multiple entities, or frequent partner movements, meeting this obligation will require planning and accurate data collection.

Understanding what AUSTRAC requires, how to prepare, and where the pitfalls lie will make the difference between a smooth enrolment and costly delays.

What enrolment means

From 31 March 2026, law firms that provide “designated services” under the AML/CTF Act must enrol with AUSTRAC as reporting entities. Enrolment is not optional: you cannot legally provide these services until you’ve completed enrolment.

Enrolment for Tranche 2 entities opens on 31 March 2026 and you must be enrolled by 29 July 2026.

What AUSTRAC needs to know

When enrolling, firms must provide:

• Designated services: which services you provide or plan to provide, including start dates and whether they are delivered in Australia or overseas.
• Business structure and professional associations: company, partnership, trust, or association. Include professional memberships (e.g. Law Council of Australia, state or territory Law Societies).
• Control: beneficial ownership, directors or partners and contact details.
• Scale: staff numbers, annual turnover, and whether you qualify as a small business.
• Reporting groups: confirmation if you are part of a reporting group and whether you are the lead. If you’re not the lead, then state who is.

Extra details for certain types of organisations

Beyond the basics, AUSTRAC also asks for extra details based on your firm’s legal structure. The common thread is the same: they want clarity on who controls and makes decisions in the organisation.

• Partnerships: details of individual partners who make key decisions (names, addresses, DOBs, government IDs) or, if partners are companies, trusts or associations, their equivalent details.
• Companies: names and dates of birth of directors, director IDs, where you’re incorporated or registered and overseas business addresses. If you have a parent company, you’ll need its name, address, country of residence and identifier.
• Trusts: type of trust, former names, and details of all trustees (individual or corporate).
• Associations or co-operatives: details of the main decision-makers (names, addresses, DOBs, government IDs).

Why this matters for law firms

• Partnership complexity: Law firms often operate as partnerships with dozens of partners across states. Enrolment requires identifying all individuals with governance authority, which can be administratively heavy.
• Multi-entity structures: Some firms use service companies or trusts alongside the legal partnership. These all need to be declared.
• Mergers and lateral hires: Frequent partner moves and firm mergers mean enrolment data can quickly become outdated. Firms need a process to update AUSTRAC whenever governance shifts.

Tips for enrolling smoothly

• Map your services: Identify which parts of your practice involve designated services (conveyancing, managing trust funds, complex corporate transactions).
• Collect the information: Gather partner or director details, including dates of birth and government IDs.
• Create an internal register: Set up a central register for governance and ownership details so you’re not scrambling across multiple spreadsheets every time AUSTRAC needs an update.
• Check structures: Define the firm’s structure before filling in the enrolment form.
• Nominate an enrolment officer: Decide who in the firm will complete and declare the enrolment.
• Plan for updates: Put systems in place to update AUSTRAC whenever partners change, services expand, or contact details shift.
• Check twice: Errors in information will slow you down.
• Use support: AUSTRAC’s helpdesk and FAQs are extensive
• Call in experts if needed: A compliance adviser can save time (and stress)
• Avoid peak times: Test the system off-peak to iron out glitches.
• Enrol early: ~90,000 companies need to register and AUSTRAC's systems will be under strain. Submitting your enrolment early gives you time to resolve any issues that may arise.

Immediate next steps

• Circulate an internal memo explaining enrolment obligations.
• Begin collating partner/director information.
• If considering a reporting group, coordinate with the proposed lead.
• Seek legal advice to align partnership deeds with enrolment requirements.