AUSTRAC Enrolment for Law Firms Under Tranche 2
Australian law firms must be enrolled with AUSTRAC under Tranche 2, which commenced on 1 July 2026. Here's what the process involves, who must enrol, and what's needed.
Australian law firms providing a designated service under the Tranche 2 amendments to the AML/CTF Act 2006 must be enrolled with AUSTRAC — Tranche 2 commenced on 1 July 2026. Enrolment is the formal notification to AUSTRAC that a firm provides a designated service. It is mandatory and separate from having a written AML/CTF programme: both are required, and enrolment alone does not make a firm compliant.
Which law firms must enrol with AUSTRAC?
Every Australian law firm — including sole practitioners — that provides at least one designated service under the AML/CTF Act 2006 must enrol. Multi-partner firms enrol once under the firm's name; individual solicitors within an enrolled firm do not enrol separately. Firms providing only non-designated services — such as criminal defence or family law advice — have no enrolment obligation.
What legal services require enrolment?
The Tranche 2 designated services that trigger AML/CTF obligations for law firms include: - Conveyancing — acting in the purchase or sale of real property - Holding or managing client trust funds in connection with a designated service - Company and trust formation — forming or dissolving companies, trusts, or partnerships - Managing client funds, securities, or assets as an agent - Business acquisitions — acting for parties buying or selling a business Pure advisory work — wills, tax advice, criminal defence — is not designated and does not require enrolment. If a firm's practice spans both designated and non-designated work, enrolment is required for the designated portion.
How does AUSTRAC enrolment work for law firms?
Enrolment is completed through AUSTRAC Online at no cost. The process requires the firm to: 1. Create an AUSTRAC Online account — using an ABN and business email 2. Select designated service categories from Schedule 1 of the AML/CTF Act 2006 3. Provide firm details — legal name, ABN, business address, and contact information 4. Nominate an AMLCO — the person responsible for the firm's AML/CTF compliance 5. Submit — AUSTRAC confirms by email; the firm receives an AUSTRAC reporting entity number Most law firms complete enrolment in 15 to 30 minutes.
Is enrolment enough to meet the Tranche 2 obligations?
No. Enrolment tells AUSTRAC you exist as a regulated entity; it does not satisfy the substantive obligations. After enrolment, a law firm must maintain a written AML/CTF programme (Part A and Part B), conduct a documented ML/TF risk assessment, apply CDD to all clients, screen for PEPs and sanctions, monitor transactions, and lodge SMRs when required. All of these obligations took effect on 1 July 2026. AMLify for law firms provides a guided programme builder to help your firm complete Part A and Part B.
Key Takeaways
- Every law firm providing a designated service must enrol with AUSTRAC before 1 July 2026 — enrolment is a free, administrative step completed through AUSTRAC Online
- Designated services include conveyancing, trust account management, company formation, and business acquisitions — pure advisory work does not trigger the obligation
- Enrolment is not compliance — a written AML/CTF programme, CDD procedures, screening, and AUSTRAC reporting must also be in place
- Get compliant now — AMLify for law firms helps most firms complete their Part A and Part B in under 30 minutes
Frequently Asked Questions
Q: Does every solicitor in a firm need to enrol with AUSTRAC?
No. Enrolment is at the firm level. The firm enrolls once through AUSTRAC Online, and individual solicitors employed at an enrolled firm do not need to enrol separately.
Q: What is the deadline for law firm AUSTRAC enrolment?
The deadline is 1 July 2026. A law firm that has not enrolled by that date will be non-compliant with the AML/CTF Act 2006 from the moment it takes effect.
Q: Does AUSTRAC enrolment cost anything?
No. Enrolment with AUSTRAC through AUSTRAC Online is free. There is no application fee, ongoing registration fee, or annual renewal charge.
Q: Can I enrol with AUSTRAC and complete my programme later?
Enrolment and programme development are separate processes and you can complete one before the other. However, the obligation to have a written AML/CTF programme also took effect on 1 July 2026, so both need to be completed together.
This is general information only and not a substitute for legal advice.