Interactive?
July 1st, 2026
1. Create an AML/CTF program
This include the following components.
ML/TF/PF risk assessment
Refers to evaluating the risks associated with a firm’s services, clients, and transactions, most commonly using a risk matrix.AML/CTF policies
Refers to the formal procedures and controls a firm must implement to comply with AML/CTF obligations, including customer due diligence, ongoing monitoring, reporting, and staff training.
⚠️ Your firm or a third party can create your AML/CTF program.
July 29th, 2026
Enrol with AUSTRAC
Since law firms will be newly regulated under Tranche 2, they must enrol with AUSTRAC within 28 days of providing a designated service.
⚠️ Law firms' enrolment deadline is NOT March 31, 2026 – the actual deadline is July 29, 2026 (28 days after July 1, 2026). A law firm's deadline to enrol is 29 July 2026 to comply and avoid penalties.
What should you do before July 1st, 2026?
Evaluation multiple AML consulting and technology vendors.
Sign up to the AUSTRAC InBrief Newsletter
https://www.austrac.gov.au/news-and-media/austrac-inbrief-newsletter
Compliance Officer
Ignore scare mongers - In NZ the equivalent of AUSTRAC, DIA took
Set up integrations with your
Staff training so your team is knowledgeable
Inform your existing clients that will be captured from July 1st
Start building out informative communications
Trial KYC providers - test the tools within your firm and with well known clients for feedback.
How can Realaml help?
Key considerations ?
If you choose a subscription based/fixed cost vendor how will you handle disbursements?
Does you outsourced provider have CAMS qualified staff?
What are their security standards for data storage?
What are their anti-fraud certifications?
- Realaml's partner, is ranked #1 globally
If your AML tech provider deletes your CDD records how will you comply with AUSTRAAC
How many countries does your
Free templates to inform you clients
Triage the next 12 - 15 months
Biggest Change for Lawyers: You Must Know Your Client (KYC) Before Acting
pros and cons between AU and NZ tranche 2
AU safe harbour doesn't include a linking mechanism like biometrics
AU doesn't require SOW and SOF for trusts
AU safe harbour has flexibility