AML/CTF Compliance Checklist for Lawyers in 2026

Legal practitioners are one of the key professions affected by Tranche 2. This checklist covers what your firm needs to have in place before the 1 July 2026 deadline.

Before you start

Understand which of your services are designated services under the Act. Not all legal work triggers AML/CTF obligations. Key areas include conveyancing, trust and company formation, financial transactions, and managing client money or assets.

The compliance checklist

1. AML/CTF Program

• Written AML/CTF program approved by a senior partner
• ML/TF risk assessment covering your practice areas, client base, and geographic exposure
• Documented CDD procedures for client onboarding
• Transaction monitoring procedures and thresholds
• Suspicious matter reporting procedures
• Record keeping policies (minimum 7 years)
• Program review schedule (at least annually)

2. Customer Due Diligence

• Client identification procedures for individuals and entities
• Beneficial ownership identification for corporate clients
• Risk rating methodology (low, medium, high)
• Enhanced CDD procedures for high-risk clients
• Ongoing CDD review procedures
• Procedures for when CDD cannot be completed

3. Screening

• Sanctions screening process (DFAT consolidated list at minimum)
• PEP screening for senior clients and beneficial owners
• Adverse media screening procedures
• Process for handling screening matches

4. Reporting

• Procedures for identifying suspicious matters
• SMR preparation and submission process
• TTR procedures for cash transactions at or above $10,000
• Tipping off obligations understood by all staff

5. Training

• AML/CTF training program for all relevant staff
• Training records maintained
• Annual refresher training scheduled
• New starter training included in onboarding

6. Record Keeping

• CDD records kept for 7 years after relationship ends
• Transaction records kept for 7 years
• Report copies kept for 7 years
• Secure storage with access controls

How AMLify simplifies this

Every item on this checklist is handled by AMLify. Ami AI generates your program, sets up your CDD workflows, runs screening automatically, and prepares your reports. Your staff can complete all 7 training modules online. Start your free trial and tick off this entire list in under an hour.