AUSTRAC updates Legal Profession Program Starter Kit

AUSTRAC has advised it made changes to its Legal Profession Program Starter Kit in June 2026.

Practitioners can access a summary of those changes on the AUSTRAC Updates page, which notes the changes in the table and tracks them in individual documents at the end of the page.

Practitioners must download the documents to see the marked-up changes because they are not visible in the web version.

A summary of those major changes are:

1. Delayed Customer Due Diligence (CDD) timeframes have changed:

• The previous January kit (v1.0) allowed a legal practice to delay completing initial CDD on a buyer in a conveyancing transaction for up to 15 days after the exchange of contracts.
• The updated June kit (v1.1) aligned with amended AML/CTF Rules by extending this delay window to 28 days after the exchange of contracts or three days prior to the initially agreed date of settlement (whichever is earliest). This applies to both conveyancing Initial CDD forms and the conveyancing Request to verify information form.

2. Streamlining beneficial ownership and entity CDD checks to enable practitioners to stop conducting beneficial ownership checks for certain customers (clients):

• Government bodies: under new CDD measures in the June kit, beneficial ownership checks have been completely removed from the Government body Initial CDD forms.
• Corporates, Partnerships, Associations, and Trusts: Terminology on the Initial CDD forms and the Legal Profession Process document, Beneficial ownership process section were updated to clarify the point at which a practitioner can legally stop tracing beneficial ownership.

3. Annual compliance reporting cycle shifts the administrative cycle to align with standard accounting practices from 31 March (January kit) of each year to on or before 30 September (June kit). The reporting period start date changed from 1 January to 1 July.

4. Risk assessments and behavioural onboarding indicators have been updated to reflect current national risk environments:

• Earlier risk identification: The June kit clarifies that indicators of unusual or criminal behaviour apply during initial CDD (onboarding), rather than only during ongoing transaction monitoring.
• New criminal indicator: Added a specific red flag under “Adverse information or suspected criminal links” in the Risk Assessment to capture clients engaged in criminal activity with a prohibited hate group.
• Emerging technology risks: The designated services risk assessment was updated to integrate new risk information regarding Artificial Intelligence (AI), Decentralised Finance (DeFi) platforms, and offshore Virtual Assets Service Providers (VASPs) based on the 2026 updates to AUSTRAC’s national risk assessments.

5. Independent evaluation flexibility:

• The January Kit outlined a strict requirement for a program evaluation every three years.
• The June Kit aligned with the AML/CTF Transitional Rules to now provide additional flexibility for the first independent evaluation. Rather than a strict three-year deadline, legal practices have been assigned staggered completion deadlines (ranging from 30 June 2029 to 31 December 2030) based on whether the last two digits of their AUSTRAC enrolment identifier are odd or even.

6. Administrative updates:

• A new Section 6 (First independent evaluation) was added to the Independent Evaluation section of the Policy Document to formally capture the transitional rules for independent evaluations.
• Enrolment Form changes: the specific name of the form used to maintain business and enrolment details in both the Policy Document and the AUSTRAC Enrolment Process Document was updated to ensure compatibility with updated AUSTRAC Online systems.

Practitioners should ensure that their program and accompanying forms are kept up to date.