Profession-specific playbook Current
AML/CTF operating playbook for legal professionals
The trigger is the specific legal service you provide, not your practising certificate.
Not every legal service is a designated service under Tranche 2. This playbook sets out how the core AML/CTF obligations apply once a legal practice is captured. It is general information, not legal or compliance advice.
Action plan
1 Confirm which of your practice's services are AUSTRAC designated services This is a service-by-service question -- general legal advice work sits differently to transaction-handling work.
AUSTRAC's AML/CTF reforms extend obligations to legal practitioners who provide specific designated services, such as receiving, holding, controlling, or managing property when assisting a client to plan or execute a transaction, or acting as or arranging a director, trustee, or nominee role. Check each service your practice provides against AUSTRAC's own designated services guidance before assuming Tranche 2 does or doesn't apply.
- Review each service line your practice offers against AUSTRAC's designated services guidance
- Don't assume general legal advice work is automatically outside scope, or that transaction work is automatically inside it
- Re-check this whenever your practice takes on a new type of matter
Done when: Your practice's service lines have been checked individually against AUSTRAC's designated services guidance, not assumed
AUSTRAC: your AML/CTF obligations2 Appoint an AML/CTF compliance officer within 28 days of providing a designated service Appointment and AUSTRAC notification are separate clocks; confirm each applicable deadline.
Once your practice provides a designated service, AUSTRAC's guidance requires an AML/CTF compliance officer to be appointed within 28 days. Notification to AUSTRAC is a separate obligation, generally due within 14 days after appointment. For newly regulated entities, the transitional notification date may instead be the later of 14 days after enrolment or 29 July 2026; confirm which timing applies to your practice. Build both obligations into your Tranche 2 readiness plan.
- Appoint an AML/CTF compliance officer within 28 days of first providing a designated service
- Notify AUSTRAC separately within 14 days after appointment, subject to the applicable transitional timing
- Confirm the appointee meets AUSTRAC's eligibility expectations for the role
- Document the appointment date to demonstrate the 28-day window was met
Done when: An AML/CTF compliance officer was appointed within 28 days of the practice first providing a designated service
See the AML/CTF compliance officer deep page3 Complete customer due diligence before starting the designated service CDD comes first -- not alongside the retainer, and not after work has started.
AUSTRAC's guidance requires initial customer due diligence to be completed before your practice starts providing a designated service to a client, with enhanced due diligence required where the client's risk is high or in other specified circumstances.
- Complete initial CDD before the designated service starts, not after
- Escalate to enhanced CDD where the client's risk is high or another specified circumstance applies
- Keep evidence of when CDD was completed relative to when the service began
Done when: CDD, escalated to enhanced CDD where required, was completed before the designated service began
See the customer due diligence deep pageDesignated services
Transaction handling
Receiving, holding, or managing property for a client transaction
Receiving, holding, controlling, or managing property while assisting a client to plan or execute a transaction is a service type worth checking specifically against AUSTRAC's designated services guidance.
Entity roles
Acting as, or arranging, a director, trustee, or nominee role
Acting as, or arranging for someone else to act as, a director, secretary, trustee, partner, or nominee shareholder for a non-natural person is a further service type worth checking individually.
Financing
Assisting with equity or debt financing transactions
Assisting a client with an equity or debt financing transaction is another service to review against AUSTRAC's own guidance rather than assuming it falls outside scope.