Industry guide
Lawyers
Solicitors performing conveyancing, trust account work, company and trust formation, or managing client money are designated service providers under AUSTRAC Tranche 2 from 1 July 2026.
Key obligations
Map your designated services
Conveyancing, trusts and estates, company formation and managing client funds are typically in scope.
Enrol with AUSTRAC
AUSTRAC enrolment is open now — sole practitioners and firms alike should enrol as soon as possible. Obligations commence 1 July 2026.
Develop a Part A and Part B program
Risk management framework + customer due diligence procedures, signed off by the principal.
Update engagement letters
Reflect AML obligations, CDD requirements and source-of-funds enquiries in client agreements.
Manage tipping-off risk
Train all staff on the prohibition against telling a client an SMR has been lodged.
Common pitfalls
Privilege as a blanket excuse
Legal professional privilege does not override AUSTRAC reporting obligations for non-privileged information.
No source-of-funds enquiries on property settlements
For high-value or unusual transactions, documenting source of funds is core CDD.
Single firm-wide risk rating
Different practice areas (conveyancing vs. corporate vs. family) carry different ML/TF risk.
Frequently asked questions
Does legal professional privilege exempt me from SMRs?
No. AUSTRAC has confirmed that privilege does not override the obligation to report suspicious matters, though privileged communications themselves can be excluded.
What about barristers?
Barristers who do not handle client money or provide designated services are generally not reporting entities.
Not sure where you stand?
Take our free 3-minute Tranche 2 readiness quiz to get a personalised risk score and next-step roadmap for your business.