New client verification requirements from 1 July 2026
From 1 July 2026, Australia’s anti-money laundering and counter-terrorism financing laws will apply to certain legal services. These reforms are part of the expansion of Australia’s AML/CTF regime to additional professional services sectors, including legal practices.
First Point Legal Pty Ltd are preparing for these changes. Where the new obligations apply to a matter, we may be required to collect and verify information about our clients, the work we are being asked to perform, and, in some cases, the individuals who own, control or act for a client.
What is changing?
The AML/CTF regime is designed to help detect and deter money laundering, terrorism financing and other serious financial crime. From 1 July 2026, legal practices that provide particular services will be subject to new compliance obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and related AML/CTF Rules.
These obligations may require us to complete client due diligence before we commence or continue certain work. Client due diligence is a regulatory process that helps us confirm who our clients are, understand the nature and purpose of the matter, and identify any relevant money laundering, terrorism financing or sanctions risks.
When might the new requirements apply?
The new requirements do not apply to every legal service. They apply to particular services that are prescribed under the AML/CTF regime. Depending on the matter, this may include legal work connected with:
- buying or selling real property;
- buying or selling a business or business assets;
- managing or controlling client money, securities or other assets;
- creating or restructuring companies, trusts or other legal arrangements;
- acting as, or arranging for another person to act as, a director, secretary, partner, trustee or nominee shareholder; or
- providing a registered office, business address or similar service for a company, trust or other legal arrangement.
If the AML/CTF obligations apply to your matter, we will tell you what information is required and why we are asking for it.
What information may we ask for?
The information we request will depend on the type of client, the nature of the matter and the level of due diligence required. We will request only the information needed for compliance purposes.
For individuals
We may ask you to provide information or documents to verify your identity, such as your full name, date of birth, residential address and current identification documents.
For companies, trusts, partnerships and other entities
We may ask for information about the entity, its structure, its directors or officeholders, its trustees or partners, and the individuals who ultimately own or control the entity. This may include information about beneficial owners, authorised representatives and persons giving instructions on behalf of the client.
For some matters
We may also need information about the nature and purpose of the matter, the source of funds or assets involved, or other supporting information relevant to our AML/CTF obligations.
Why are we asking for this information?
We are asking for this information because, from 1 July 2026, the law may require us to complete client due diligence and ongoing monitoring for certain legal services. These processes are not unique to our firms. They form part of a broader national framework administered by AUSTRAC, Australia’s AML/CTF regulator and financial intelligence unit.
Providing this information helps us meet our legal obligations and assists in protecting clients, the legal profession and the Australian community from the misuse of legal services for financial crime.
When will information be requested?
Where the new obligations apply, we may ask for information:
- before opening a new matter;
- when commencing a new engagement for an existing client;
- during an existing matter, if additional due diligence is required;
- when there is a change in ownership, control, instructions or matter circumstances; or
- when we are required to update or refresh information previously provided.
No action is required unless we contact you directly. If information is needed, we will explain the process and the documents or details required.
How we will handle your information
We recognise that client verification may add an administrative step to your matter. Our aim is to make the process as efficient and straightforward as possible.
Information provided to us will be handled securely and consistently with our privacy, confidentiality and professional obligations. We will use the information for compliance, client onboarding, risk management and related legal practice purposes. We will not ask for more information than is reasonably required for those purposes.
What you can do to assist
- If we contact you for information, you can assist by:
responding promptly to requests for identification or supporting documents; - ensuring that documents are current, complete and legible;
- telling us if the person instructing us is acting on behalf of another person or entity;
- advising us of any changes to ownership, control, authority or contact details; and
contacting your usual lawyer if you are unsure why information has been requested.
Will this delay my matter?
In most cases, the verification process should be straightforward. However, where the AML/CTF obligations apply, we may need to complete required checks before we can commence or continue certain work. Providing requested information early will help avoid unnecessary delay.
Frequently asked questions
Do the new AML/CTF requirements apply to all legal matters?
No. The requirements apply to particular services prescribed under the AML/CTF regime. If they apply to your matter, we will tell you what information is required.
I am an existing client. Why do you need to verify my identity again?
The new regime may require us to verify or update information for existing clients when a new matter is opened, when a prescribed service is provided, or when relevant circumstances change. Prior dealings with our firms may not remove the need to complete current AML/CTF checks.
What happens if I cannot provide the requested information?
If required information is not provided, we may be unable to commence or continue work on the matter until the issue is resolved. We will discuss any practical issues with you if they arise.
Will my information be kept confidential?
Yes. We will handle information securely and consistently with our privacy, confidentiality and professional obligations. In limited circumstances, AML/CTF laws may impose reporting obligations on regulated entities. Where those obligations apply, they must be managed in accordance with the law.
Where can I find more information?
Further information about Australia’s AML/CTF reforms is available from AUSTRAC. You may also contact your usual First point legal lawyer if you have questions about how the changes may affect your matter.
Need assistance?
If we require information from you, we will contact you directly and provide clear instructions. If you have received a request and have questions about what is required, please contact the lawyer or team managing your matter.