Certainty still missing in AML CTF roll-out
10 June 2026
With just three weeks until the Tranche 2 Anti-Money Laundering and Counter-Terrorism regime commences, the Law Council has warned more time is needed for the small businesses that make up more than 90 percent of the Australian legal profession to prepare to comply with reforms that many are still not even sure if they will be subject to.
Appearing before the Parliamentary Joint Committee on Intelligence and Security (PJCIS) yesterday, the Law Council expressed serious concern about the ongoing lack of certainty regarding important aspects of the reforms.
“Until clarity is provided on who the regime actually applies to, commencement should be delayed. Three weeks is simply not enough time for small businesses to prepare for obligations they cannot yet identify,” Law Council of Australia President, Tania Wolff said.
"Despite the best efforts of the profession and significant work by the regulator, a lack of clarity in the legislation means it is still not clear what legal services are caught up in the regime.
"Even now, practitioners and firms across the country cannot determine whether they provide a 'designated service' and therefore face prescribed obligations from 1 July."
The situation is further complicated by amendments to the regime currently before Parliament, which are the subject of this week's PJCIS inquiry. Rather than resolving the uncertainty, the Law Council warned these amendments risk deepening it.
Ms Wolff called for commencement of the reforms, or at least certain parts of them, to be delayed by 12 months. Should that not be possible, she urged AUSTRAC to implement a transitional compliance period of at least 24 months focused on education and assistance rather than enforcement.
"The Law Council remains committed to working with the Government on these reforms. Money laundering and terrorism financing cause real harm, and the legal profession takes that seriously,” Ms Wolff said.
“But regulated entities cannot comply with obligations they cannot identify."
Contact
Kristen Connell
T. 0400 054 227
E. kristen.connell@lawcouncil.au
Last Updated on 19/06/2026