What does an AML/CTF program look like for a small to mid-sized law firm?
Every law firm that provides a “designated service” must establish and maintain an anti-money laundering (AML) and counter-terrorism financing (CTF) program. Think of it as the rulebook your firm writes for itself, setting out how your firm identifies, assesses and manages AML/CTF risk.
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) (Act) requires there to be two parts to an AML/CTF program:
Part A: Firm-wide policies, procedures and controls. This includes appointing a compliance officer, conducting risk assessments, setting escalation processes, staff training, and independent review.
Part B: Customer due diligence procedures — how your firm verifies clients, beneficial owners, and ongoing monitoring.
What does AUSTRAC expect?
AUSTRAC doesn’t prescribe one template. Instead, your firm’s program must be fit for purpose and documented. For a small to mid-sized law firm, expect:
A nominated Compliance Officer with authority.
A written money laundering and counter terrorism risk assessment.
Risk-based customer due diligence procedures for client intake.
Policies on reporting (suspicious matter reports, threshold transactions).
Training modules for staff.
Independent reviews.
AUSTRAC sees the AML/CTF program as the heart of compliance. If your firm doesn’t have one, or if it exists only on paper, your firm risks regulatory action and reputational harm. A good AML/CTF program also protects your firm — when tough client decisions arise, your firm has a clear policy to rely on.
We are well placed to assist you with all of these requirements – register for a webinar or give our AML/CTF team a call.
Paul Gray
Principal
T 03 5225 5231 | M 0414 195 886
E pgray@ha.legal
Hugo Le Clerc
Senior Associate
T: 03 5225 5213 | M: 0438 089 334
E: hleclerc@ha.legal
