New Anti-Money Laundering Requirements for Legal Services
From 1 July 2026, Australian law firms are subject to new obligations under Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime.
These changes are designed to help prevent the misuse of legal services for money laundering, terrorism financing, fraud, sanctions evasion and other financial crimes.
As a result, there have been some changes to how we onboard clients, accept instructions and provide legal services including the provision of documents.
Documents that require CDD
Since the commencement of the new regime, we have been refining our internal processes based on better guidance material recently released on how the legislation applies across our various service offerings.
Unless a reliance method applies (discussed below), we understand that we are generally required to carry out customer due diligence (CDD) and ID Verification for the following documents:
- New SMSFs
- New Companies
- New trusts (eg, family and unit trusts)
- LRBA documents
Most other documents we provide will not require our own CDD (ie, SMSF deed updates, changes of trustee, change of members, other trust variations, pensions, constitution updates, etc).
Reliance methods
For firms that have AML/CTF procedures in place, we can also implement reliance methods, where we can rely on CDD already undertaken by another firm in appropriate cases. This is allowed under the AML/CTF rules and can streamline orders as broadly speaking we rely on CDD carried out by another firm.
There are two types of reliance methods:
- case-by-case reliance; and
- ongoing CDD reliance arrangements.
Reliance would only be appropriate where the entity we rely on for CDD is also enrolled with Austrac and has its own AML/CTF obligations. Such an entity must also have appropriate AML policies and procedures in place.
If you are interested in using reliance with us, please contact us at [email protected].
Who will need to undertake ID Verification
Depending on the type of client and matter, our CDD may include verifying the identity of:
- individuals;
- trustees of SMSFs and other trusts;
- directors and shareholders of companies;
- SMSF members and beneficiaries of trusts; and
- appointors of trusts.
Where CDD is relevant, You (eg, the adviser or person ordering) should expect to provide additional information about individuals before we can progress our work on some matters.
- You should expect to be asked for the following information for individuals involved in these entities:
- full name;
- date of birth;
- residential address;
- email address;
- mobile number; and
- for directors, their director identification number.
We may also ask questions about an individual such as whether they, a family member or an associate is a politically exposed person (PEP), or if they are subject to financial sanctions.
Verification process
When you order through our online portal, or otherwise commence a matter requiring CDD, this will trigger a process where we send an email to the individuals involved to carry out a verification process via our third-party provider, VerifiMe. https://www.verifime.com/
This process will typically include uploading a photo ID of the individual. The easiest way to complete the verification process is with the use of a smartphone, although this can be done via a computer.
We will not receive or retain copies of ID documents.
Will this impact timeframes?
Yes; where CDD is required, additional time is involved before we can release documents.
The timeframe for us to provide documents is dependent on the time it takes for the individuals involved to carry out the verification process.
To minimise delays, we recommend that you notify clients that they will be receiving an email from DBA Lawyers or VerifiMe that will refer to DBA Lawyers and which will ask them to complete a verification check, and encourage them to complete the process as soon as possible. An advance email from you will also provide them notice to expect our email and reduce the risk of our email being deleted or ignored.
There may be circumstances where delays occur due to a person not passing the verification process or a matter being particularly complex.
We appreciate your cooperation
We understand these additional requirements may create some extra administration and hassle.
Our team is committed to making the process as efficient and straight forward as possible. We appreciate your cooperation and patience as we implement these changes and welcome any feedback about the processes.
If you have any questions about what’s changing, please contact our office or email Shaun Backhaus ([email protected]), Director, DBA Lawyers.
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DBA LAWYERS
9 July 2026
