How did we get here?
Anti-Money Laundering (AML) refers to a set of laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income. The goal of AML is to detect and report suspicious financial activity that may be linked to crimes such as drug trafficking, human exploitation, weapons dealing, fraud, corruption, tax evasion, or terrorism financing. Money laundering can undermine the integrity of financial systems, facilitate criminal enterprises, and damage economic stability. AML frameworks help protect institutions and society from these risks. Practitioners are an integral part of these transactions.
History of AML in Australia
The AML/CTF regime was introduced to bring Australia into compliance with international standards published by FATF to reduce the risk of Australian businesses being misused for money-laundering and the financing of terrorism. FATF was originally founded to deal with the laundering of proceeds of drug cartels in the 1980’s.
The AML/CTF Act was passed in 2006 and was phased in over two years. Known as Tranche 1, the reforms commenced in 2008 and regulated the bullion, gambling, financial and remittance service industries where the conversion and transfer of physical and electronic forms of money were seen as vulnerable to money laundering and terrorism financing. Lawyer’s trust accounts were specifically exempt from the Tranche 1 regime.
What do I need to do right now?
The reforms take effect from 1 July 2026. Start preparing immediately with the following steps:
What do I need to know?
If you’ll be a reporting entity, these are the key requirements.
Practitioners are prohibited from disclosing information (including the fact that you have submitted a SMR – s123) to a client if it would or could reasonably be expected to prejudice an investigation.
What’s Coming Up?
- January 2026 – Starter Program Kit published
- 31 Mar 2026 – AUSTRAC enrolments open
- 1 Jul 2026 – Obligations commence
Checklist for 1 July 2026
- Enrolled with AUSTRAC
- Have an AML/CTF program (risk assessment, policies, procedures, controls)
- Appoint governing body, Compliance Officer, and Senior Manager
- Train staff on AML/CTF obligations and ML/TF risks
- Be ready for ongoing CDD
- Be ready to submit Suspicious Matter Reports (SMRs)
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Anti-Money Laundering & Counter Terrorism Financing
Join Matt Dunn, CEO of QLS, and Ian Lockhart, Partner at MinterEllison, as they discuss the latest updates in Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF). In this expert conversation, they dive into key regulatory changes, emerging risks, and what businesses and legal professionals need to know to stay compliant.
New Zealand's anti-money laundering and counter-terrorism financing regime
QLS is planning for the awareness, education and guidance of the legal profession for the upcoming anti-money laundering and counter-terrorism reforms.
Consultations and Submissions
QLS and the Law Council of Australia have undertaken advocacy on this issue since 2007.