Our Approach To
Anti Money Laundering / Counter Terrorism Financing
From 1 July 2026, amendments to federal Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws will require firms like ours to complete additional identity checks before we can provide certain services.
These changes are designed to help prevent money laundering by criminal organisations and the funding of terrorist groups.
This page contains information on:
What AML/CTF is and why we have to complete identity checks
Which services are affected (designated services)
What documents you may be asked to produce
How the process works
Our commitment to privacy and secure data handling.
We will continue to update this page as more information comes to light.
What is AML/CTF and why are we obliged to comply?
Australia’s AML/CTF laws are expanding to cover additional professional services, including law firms, from 1 July 2026.
In practice, before we commence providing clients with a designated service, we will need to:
Collect information about our clients and verify their identity
Understand the purpose of the matter or transaction
Assess and document any money laundering and terrorism financing risks
Keep clear records of our decisions
Important: We are legally required to undertake these activities to comply with these requirements.
Which services are affected (designated services)
Not all services provided by our firm are subject to AML/CTF legislation. Whether AML applies depends on whether we are providing a “designated service” for your matter.
Designated services for professional services typically include where we assist with:
Buying, selling or transferring real estate (for example, supporting a property transaction)
Buying, selling or transferring a company or legal arrangement (for example, aspects of a business sale or transfer)
Receiving, holding or managing client property or funds to help plan or execute a transaction (where relevant to the service being provided)
Arranging or assisting with equity or debt financing for a company or legal arrangement
Selling or transferring a shelf company
Creating or restructuring a company or legal arrangement (for example, certain entity or trust structuring work)
Acting on behalf of someone in certain roles or nominee arrangements for a company or legal arrangement
Providing a registered office or principal place of business address for a company or legal arrangement
At the start of each matter, we’ll confirm whether the work involves a designated service and what level of checks are required.
What documents might I be asked to produce?
The amount of documentation you will be required to provide will depend on the AML/CTF risks associated with the client and the services being performed. Typically, clients will be required to provide the following documents:
Photo ID (for example, passport or driver’s licence)
Proof of address (for example, utility bill or bank statement)
Company, trust or SMSF documents (if relevant)
Ownership and control information for complex entities
Source of funds information (for higher-risk matters)
If you are acting for a company, trust or other structure, we will need to identify and verify the individuals who ultimately own or control it.
Key Data Security Point: We will not hold copies of any of these documents. You will provide these via a secure platform purely for this verification process.
What questions might I be asked?
As part of our AML/CTF obligations, we may ask you for additional information to help us verify your identity, understand who we are acting for, and determine whether any additional due diligence is required.
This may include asking whether you, your representative, or your immediate family members or close associates are or have been politically exposed persons (PEPs).
A PEP is generally someone who holds, or has held, a prominent public position in Australia, overseas, or in an international organisation. This can include senior politicians, judges, ambassadors, senior military officers, senior government officials, and senior officers of state-owned entities or international organisations.
Below are definitions of different types of politically exposed persons (PEPs). Consider if you or your representative are a politically exposed person.
Note: Family members and close business associates of persons who hold one of these positions are also considered politically exposed persons.
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A foreign PEP is an individual who holds or has held a prominent office or position or public function in or for the legislature, executive or judiciary of a foreign country.
This includes an individual who holds or has held any of the following offices or positions:
head of state or head of government
member of the executive council of government
member of a legislature
minister, deputy minister or equivalent office or position
judge of a supreme court, constitutional court or other court of general jurisdiction or last resort
ambassador, high commissioner or charge d’affaires
high ranking military officer
head or board member of a government body
head or board member of a state‑owned company or a state‑owned bank
member of a governing body of a political party represented in a legislature.
A foreign PEP is also a family member of an individual listed above or an individual who is known (based on information that’s public or readily available) to have:
joint beneficial ownership of a body corporate or legal arrangement with an individual listed above
sole beneficial ownership of a body corporate or legal arrangement on behalf or for the benefit of an individual listed above
any other close business relations with an individual listed above.
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A domestic PEP is an individual who is in or has been in the following office or position:
member of the legislature of the Commonwealth or a state or territory
member of the governing body of a political party represented in the legislature of the Commonwealth or a state or territory
Governor‑General
governor of a state
administrator of a territory
Justice of the High Court
Judge of the Federal Court of Australia
Judge of the Supreme Court of a state or territory
accountable authority, or member of the accountable authority, of a Commonwealth entity within the meaning of the Public Governance, Performance and Accountability Act 2013 (PGPA Act) (for example a Secretary of a Department of State or parliamentary department)
member of the governing body of a wholly‑owned Commonwealth company within the meaning of the PGPA Act
head (however described) of a department of state or territory, or an agency or authority of a state or territory that has a prominent public function
head (however described) of a local government council in a state or territory
the chair of the board, chief executive officer or chief financial officer of a company or other incorporated body that’s wholly‑owned or majority‑owned by a state or territory
Chief of the Defence Force, Vice Chief of the Defence Force, Chief of Navy, Chief of Army or Chief of Air Force
officer of the Navy of the rank of Vice Admiral or a higher rank
officer of the Army of the rank of Lieutenant General or a higher rank
officer of the Air Force of the rank of Air Marshal or a higher rank
any of the following offices of the Commonwealth in a foreign country, or to a public international organisation, to which appointments are made by the Governor‑General:
Ambassador
High Commissioner
Consul‑General
Australian representative
special representative
representative
permanent representative
Chargé d’Affaires.
A domestic PEP is also a family member of an individual listed above, or an individual who is known (based on information that’s public or readily available) to have:
joint beneficial ownership of a body corporate or legal arrangement with an individual listed above
sole beneficial ownership of a body corporate or legal arrangement on behalf or for the benefit of an individual listed above
any other close business relations with an individual listed above.
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An international organisation PEP is an individual that is entrusted or has been entrusted with a prominent public function, position or office of a public international organisation. This includes a head, deputy head or board member in a public international organisation, such as a United Nations body.
An international organisation PEP is also a family member of one of these individuals, or an individual who is known (based on information that’s public or readily available) to have:
joint beneficial ownership of a body corporate or legal arrangement with an individual entrusted with a prominent public function, position or office of a public international organisation
sole beneficial ownership of a body corporate or legal arrangement on behalf or for the benefit of an individual entrusted with a prominent public function, position or office of a public international organisation
any other close business relations with an individual entrusted with a prominent public function, position or office of a public international organisation.
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A family member includes:
a spouse, de facto partner, or equivalent under any applicable law of a foreign country, of the individual
a child of the individual
a spouse or de facto partner, or equivalent under any applicable law of a foreign country, of a child of the individual
a parent of the individual.
How the process will work
Our process is designed to be clear, efficient and secure. The speed at which this process is completed is dependant on the nature of your matter, most clients complete it quickly once documents are provided. This process will occur once you have made contact with us to provide you with a service.
Scope the matter
A Harwood Andrews representative will gather information from you regarding your matter to determine whether the service we will provide is a designated service that will require AML/CTF checks. If your matter does fall under a designated service, you will incure a small charge for the AML check on your cost agreement.
Scope of engagement provided
You will receive a scope of engagement letter that will include our cost agreement and terms of trade.
Agree to commence engagement
If you agree to the scope, terms and costs you will sign the agreement and if the service is a designated service, we will commence the AML requirement gathering.
Share your details
You will be sent an email from our integrated and secure identity verification partner First AML to request your identity information and any relevant documents.Verify your information
First AML’s platform will step you through securely providing identity and ownership details.Clarify anything missing
If further documents or explanations are required, we will contact you promptly.Reports received
We will receive a report from First AML summarising your identification checks.
Complete the assessment
We will review the report and finalise the risk assessment.
We begin working with you
Once checks are complete and we are satisfied with the assessment, we can commence work on your matter.
Our Commitment to privacy and secure data handling
We take privacy and data security seriously. Information you provide is handled in accordance with:
Australian privacy laws
Our professional confidentiality obligations
AML/CTF regulatory requirements
Your data is used only for identity verification, compliance checks and onboarding purposes. We do not use it for marketing and we don’t sell or trade client data.
We have integrated a third-party identification platform called First AML to perform these checks and do not store your personal identification documents.
All data transmitted and stored via the First AML platform is encrypted both in transit and at rest using the industry standard AES-256 encryption algorithm to encrypt data. First AML production data and systems are hosted in Amazon Web Services (AWS), and physical security is managed by AWS at the Perimeter, Infrastructure, Data and Environmental layers.
Need Help?
If you have any questions about the changes to the AML/CTF legislation or what we need and why, please contact our compliance team.