‘One step at a time but get started now’ is AUSTRAC’s message to practitioners as the 1 July deadline for the anti-money laundering and counter-terrorism financing rules looms.
While developing a program is important, AUSTRAC Deputy CEO, Regulation, Katie Miller said there’s a misconception that the regulatory agency wants immediate perfection.
“Money laundering is a complex area. It does take a bit of time to get your head around how the criminal mind works and how people who look legitimate can, in fact, be criminals hiding in plain sight, or people assisting criminals hiding in plain sight,” Ms Miller said.
“So, we don’t expect perfection day one. What we do expect is effort, and there are a couple of threshold matters that need to be done by day one,” she said.
Noting the enrolment process is starting on 31 March, Ms Miller urged firms to download the program starter kits the regulator had recently released.
“People need to have a program,” Ms Miller said. “[The program starter kits] provide a guide for small practices providing services predominantly to consumers.”
“My strong encouragement to everyone is to follow the guide that is on the website in the order that we’ve set out.”
“We tried to break it down as much as possible, so lawyers don’t need to engage with all of the content the first time they open up the guide.”
Ms Miller said it was a case of going through the guide section by section.
“Start with the risk assessment, then go to the policy, and go to the procedures, and then there’ll be some forms you need to download,” she said.
“I would strongly encourage people not to jump around the process and just follow the steps that we’ve got on the website.”
She said the program starter kits were a world first and the first time that a regulator has stepped into the shoes of a regulated business and said, ‘this is how you actually set up a program’.
“It was really about trying to relieve the regulatory burden,” Ms Miller said.
“We know there was a lot of anxiety about the cost, whether it be the cost of an individual lawyer having to sit down and figure this out from scratch, or whether it was the cost of getting an external provider to provide a program.”
A former President of the Law Institute of Victoria, Ms Miller said that background gave her some insight into the how hard it is to run a law firm.
“There’s lots of obligations. You’ve got a lot of demands on your time, and if we can reduce the amount of time lawyers need to meet their obligations, it means that we free them up to do what they actually got into the profession to do,” she said.
“And that is to provide legal services to clients, to help solve legal problems, prevent legal problems and, ultimately, meet the legal needs of the community.”
The advice comes as the QLS roadshow got underway this week, with Ms Miller saying member organisations are important pieces in the implementation puzzle.
“We recognise that busy practitioners, working in the suburbs, they’re not going to be spending every minute on our website looking for updates,” she acknowledged.
“They’re going to go to a source that they trust, and that’s generally going to be their professional association.
“It is new, but it is something that they will be able to learn and incorporate into their practice. They’ve got support to do that as a regulator, and we are keen to set people up for success, but I know that a lot of people will feel much more comforted knowing that their professional association is there to help along the way as well.”
Katie Miller will be presenting at QLS Symposium 2026 on the topic of Source of Funds & Source of Wealth: Questions your clients might not like, but you must ask. To find out more about her presentation and for the full program visit QLS Symposium 2026.
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