Tranche 2 · Lawyers
AML compliance designed for legal practice
Law firms assisting with real estate transactions, buying/selling entities, managing client property/funds, or certain trust/company services are reporting entities. Designated services include assisting buy/sell/transfer of real estate or entities; receiving/holding/managing property in transactions; acting as trustee. Mixed practices should use both Legal and Conveyancing Starter Kits.
Am I captured?
Trigger is the service, not the practising certificate.
Designated services include:
- Assisting a client to buy, sell or transfer real estate
- Assisting a client to buy, sell or transfer a company or other entity
- Receiving, holding or managing property or funds in a transaction
- Acting as trustee, or providing certain trust and company services
Mixed practices should treat legal and conveyancing work separately if both are offered.
Your obligations
If you provide a designated service, you are a reporting entity. You must enrol with AUSTRAC, run a risk-based AML/CTF program, identify and monitor clients, keep records and report when the law requires it. For law firms that usually means property, entity and funds work on a file — not courtroom advocacy or general advice that never touches a designated service.
AUSTRAC enrolment
Enrol with AUSTRAC and keep the enrolment current — including nominating a Compliance Officer. Enrolment is how AUSTRAC knows you are a reporting entity and how it contacts you.
Risk assessment
Document how your firm could be used for money laundering or terrorism financing — clients, services, delivery channels and geography — and keep that assessment current as the practice changes.
AML/CTF program
Put in writing how the firm will meet its AML/CTF duties: who does what, how clients are identified, how higher-risk work is handled, how staff are trained and how you will check the program still works.
Customer due diligence
Identify the client (and beneficial owners where relevant), verify that identity, screen for PEPs, sanctions and adverse media, and apply extra checks when risk is higher. Repeat when circumstances change.
Reporting
Submit suspicious matter reports to AUSTRAC when you form a suspicion, and any other reports that apply to your services. Do not tip the client off that a report has been made or is being considered.
Record-keeping
Keep the program, risk assessment, identification records and transaction records for at least seven years so you can show AUSTRAC what you did and why.
How Trancher helps
Sits alongside how legal work happens — not a banking-style process. Clear designated-service guidance, tailored program, efficient CDD, higher-risk/PEP handling, tipping-off-aware reporting and a full audit trail.
Risk assessment and AUSTRAC-aligned program builder
Client verification (KYC/KYB) with PEPs, sanctions and adverse media screening
Ongoing monitoring and risk scoring
Reporting support (SMRs)
Staff training modules
Audit-ready records and dashboard
Three clear paths
Choose the level of support that works for your firm — manage compliance yourself, add expert support when you need it, or have agreed activities managed for you.
1
Self-managed
Run your AML program through Trancher using clear workflows and built-in guidance.
From $9.99 per week.
2
Self-managed + expert support
Use the platform day to day and bring in our compliance specialists when you need help with set-up, risk assessment, program development, onboarding, training or first files.
3
Fully managed by our experts
Ask our experienced compliance specialists to manage agreed AML compliance activities on your organisation’s behalf.
How long does it take?
Most firms move from start to operational compliance within weeks.
Days 1–7
Enrolment and risk assessment underway
Days 8–21
Workflows live and team trained
Thereafter
Fully operational and audit-ready
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Am I captured?
Trigger is the service, not the practising certificate. Designated services include assisting a client to buy, sell or transfer real estate; assisting a client to buy, sell or transfer a company or other entity; receiving, holding or managing property or funds in a transaction; and acting as trustee or providing certain trust and company services. Mixed practices should treat legal and conveyancing work separately if both are offered. Courtroom advocacy or general advice that never touches a designated service is not captured.
What are the deadlines?
Tranche 2 obligations commenced on 1 July 2026. Firms already providing designated services on that date needed to enrol with AUSTRAC by 29 July 2026. If you start providing a designated service later, enrol within 28 days of first providing it. Nominate an AML/CTF Compliance Officer and keep your enrolment current. Mixed practices should enrol against the services they actually provide.
What goes in the program?
Your AML/CTF program must include a written risk assessment and the policies, procedures, systems and controls to manage ML/TF risks and meet your obligations. For law firms this typically covers client identification and verification on property, entity and funds files; beneficial ownership; PEPs/sanctions/adverse media screening; higher-risk and PEP handling; tipping-off-aware reporting; staff training and record-keeping — tailored to the designated services on your matters.
What does CDD look like in practice?
Identify the client (and beneficial owners where relevant), verify identity, and screen for PEPs, sanctions and adverse media before or as you provide a designated service. Enhanced checks apply where risk is higher. In a law firm this is most relevant on conveyancing or entity transactions, when holding client funds or property, or when acting in certain trustee or nominee roles. Records stay with the matter file so you can demonstrate what was checked.
How is KYC/KYB charged?
Every verification check triggers one transaction. If you are identifying individuals within an entity (for example directors, beneficial owners or authorised persons), each individual check is a separate transaction and is charged accordingly.
Disclaimer
This is a plain-English guide only and is not a determination of your firm’s status. Whether you are a reporting entity depends on the specific designated services you provide, the facts of each engagement, and the applicable items in the AML/CTF Act. If unsure, use the Am I in scope? guide or seek independent legal advice. Trancher does not provide legal advice.
Ready to simplify compliance?
Book a short overview or speak with our in-house specialists about the right path for your firm.