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.
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 the 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 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, terms of trade, and the details of the scope of our engagement.
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 requirements.
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’ll 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 matter 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.