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AML/CTF enrolments open tomorrow – what Queensland solicitors need to know

QLS Director of Ethics Grace van Baarle was part of the AML/CTF panel which toured Queensland.

Australia’s long‑anticipated Anti‑Money Laundering and Counter‑Terrorism Financing (AML/CTF) reforms for the legal profession take their first practical step tomorrow, with the regulator, AUSTRAC opening enrolments for solicitors on 31 March 2026.

From tomorrow, any practitioner who provides a designated service under the AML/CTF Act will need to enrol with the regulator.

While the legislation allows 28 days from when a practitioner first provides such a service, Queensland Law Society (QLS) is urging firms to complete enrolment by 1 July to avoid non‑compliance as the new regime begins.

QLS Director of Ethics Grace van Baarle said the shift represented a significant regulatory change.

“The earlier you begin preparing your information for enrolment, the smoother this transition will be,” she said.

“We encourage practices to diarise this now and act promptly once the AUSTRAC form becomes available.

“However, we do anticipate that the AUSTRAC website may be quite busy during the first few days as it is anticipated that potentially 90,000 new reporting entities will be required to enrol. Perhaps wait a couple of days.”

Why solicitors are being brought into the AML/CTF regime

Enrolment marks the first phase in the Federal Government’s plan to expand AML/CTF obligations to Tranche Two professions, including lawyers, accountants and real estate agents.

The global Financial Action Task Force (FATF) has for more than a decade pressed Australia to regulate these sectors due to their involvement in high‑risk transactions, such as property dealings, company structures and the movement of client funds.

Under the government’s staged model, enrolment comes first, creating a foundation for later obligations around risk assessments, customer due diligence, ongoing monitoring and reporting.

QLS continues to advocate for a proportional and practical rollout, particularly for small and medium‑sized practices.

“Solicitors are committed to integrity and ethical practice,” Ms van Baarle said. “What members need now is clarity, time and support in meeting these new obligations in a way that works for the realities of legal practice.”

AUSTRAC will release a dedicated online enrolment form. Until then, practitioners can begin preparing the information required under Rules 3‑2, 3‑3 and 3‑5.

What information practitioners must provide

1. Designated Services (Rule 3‑2)

Practitioners must outline:

  • A description of the designated services you provide or intend to provide;
  • The date each service commenced or will commence;
  • Whether the service is provided through a permanent establishment in Australia; a permanent establishment in a foreign country; or a permanent establishment overseas as a subsidiary of an Australian resident company;
  • The industry in which the designated services are provided.

2. Information about the applicant (Rule 3‑3)

Firms must provide detailed business information, including:

  • Full legal name and any registered or trading names;
  • ABN, ACN, ARBN and/or ARSN;
  • Registered office and principal place of business;
  • Legal structure (e.g. ILP, partnership, trust);
  • Number of employees;
  • Contact details;
  • Website domain names;
  • Description of the practice;
  • Beneficial ownership;
  • Approximate annual turnover;
  • Legal Entity Identifier (if applicable);
  • Contact for AUSTRAC Industry Contribution Act communications;
  • Small business entity status;
  • Professional association memberships.

Additional information is required for body corporates, government bodies, partnerships, trusts, associations/co-operatives and reporting groups.

3. Individual completing the enrolment (Rule 3‑5)

Practitioners must provide the full name, position, contact details and a declaration confirming that the information supplied is true and correct.

Keeping information up to date

Once enrolled, practices must keep their details current and notify AUSTRAC of any changes within 14 days. This is an ongoing obligation, not a one‑off administrative step.

What this means for firms

With enrolments opening, many firms are now assessing what changes may be needed internally. Some will find the process straightforward; others, particularly multi‑office or multidisciplinary practices, may need coordinated work to identify which services are designated and confirm beneficial ownership information.

Although concerns remain about regulatory burden, QLS says practitioner engagement has been strong.

Ms van Baarle said many Queensland practitioners had already taken steps to prepare.

“Once it became clear these reforms were coming, many legal practices immediately started preparing,” she said.

“What we’re hearing is not resistance, but a genuine desire for clarity, guidance from the regulator and lead time, and that’s what we’ll keep advocating for.”

The period between March and July is expected to be a settling‑in phase as firms navigate the enrolment process and begin considering how later stages of the regime may affect trust accounting, client onboarding and governance systems.

While enrolment is only the beginning, it represents a major cultural shift. For the first time, the legal profession will join banks and other regulated industries in Australia’s broader effort to identify and disrupt financial crime.

“We know practitioners will rise to this challenge and are incredibly capable,” Ms van Baarle said. “Enrolment is simply the point at which that journey begins.”

AUSTRAC’s enrolment form and associated guidance will be released soon. For more information you can visit the QLS website.

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