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From 1 July 2026, law firms and conveyancing practices in Australia become reporting entities under the AML/CTF Act. The Tranche 2 reforms require you to verify every client receiving a designated service, implement a written AML/CTF Program, and report suspicious activity to AUSTRAC. This guide explains what is required and how ClearAML supports your practice.

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Why lawyers and conveyancers are affected

Legal professionals are among the most exposed “gatekeeper” professions identified by AUSTRAC. Property transactions, trust accounts, and corporate formation work are all high-value channels that can be exploited to move illicit funds. The Tranche 2 reforms target the following designated services:
  • Conveyancing — acting on the purchase, sale, or transfer of real property
  • Trust account transactions — receiving, holding, or disbursing client money through a trust account
  • Legal entity creation — forming companies, trusts, or other legal structures on behalf of a client
  • Asset transactions — facilitating the transfer of business assets or managing client assets
The obligations apply even if you are acting as an intermediary rather than the principal. If you are facilitating the transaction on behalf of a client, you are the reporting entity.

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Key obligations under Tranche 2

Before providing any designated service, your firm must:
  1. Enrol with AUSTRAC as a reporting entity (enrolment deadline: 29 July 2026)
  2. Appoint a Compliance Officer to own your AML/CTF Program
  3. Implement a written AML/CTF Program covering your firm’s risks
  4. Verify the identity of each client (KYC) before providing designated services
Obligations are live from 1 July 2026. Penalties for non-compliant corporations can reach 22.2millionpercontravention∗∗.Forindividuals,themaximumis∗∗22.2 million per contravention**. For individuals, the maximum is **2.22 million per contravention.
1

Create a client profile for each matter

Add clients manually or import your existing client list. ClearAML supports matter-based filing so you can organise compliance checks by matter number, not just client name — essential for high-volume practices handling multiple files per client.
2

Send a secure verification link

With one click, send your client a secure link they complete on their phone. They upload or photograph their identity document, complete a biometric liveness check, and submit. You receive the verified result — no office visit required.
3

Trace beneficial owners

For company clients, ClearAML performs automatic beneficial owner (UBO) tracing by looking up ASIC registers. This satisfies the enhanced due diligence (EDD) requirements for corporate clients and gives you a documented ownership map.
4

Screen for PEPs and sanctions

Every client is screened against global Politically Exposed Person (PEP) and sanctions watchlists. Matches are flagged for your review before the matter proceeds.
5

Generate ARNECC-compliant VOI records

ClearAML’s biometric liveness checks and DVS integration meet ARNECC standards for digital Verification of Identity (VOI) under the Model Participation Rules — suitable for both legal intake and electronic conveyancing settlements.
6

Store everything in the forensic audit log

Every check and decision is time-stamped and stored. Your compliance records are retained in Australian data centres in line with the 7-year record-keeping requirement and are always ready for AUSTRAC review.

Trust account KYC

Any client whose funds pass through your trust account requires verified identity. ClearAML links each verification to the relevant client file so you have a complete, auditable record for each matter.

Conveyancing KYC

Verify vendors, purchasers, and mortgagors as part of your settlement workflow. ClearAML meets ARNECC’s digital VOI standards so you can complete verification remotely without requiring clients to attend your office.

Beneficial owner tracing

For company or trust clients, automatically trace and document the ultimate beneficial owners (UBOs). The ownership graph shows exactly who controls the entity at every tier.

Matter-based filing

Organise all compliance checks by matter number. Each matter contains its own verification records, risk assessments, and audit log — making end-of-matter reporting straightforward.

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Key features for law firms

Send a secure link to your client. They verify on their phone in minutes. You receive a compliant VOI report instantly. This eliminates the time and cost of in-person identity checks at listing or signing.
ClearAML generates a tax invoice for every check. You can list the AML/VOI check as a standard disbursement on your client’s final bill — so compliance does not eat into your firm’s margin.
The risk engine calculates scores based on client type, industry, and geography. High-risk clients are flagged automatically so your team focuses enhanced due diligence where it is actually needed.
Every action — every click, status change, and risk decision — is time-stamped in a tamper-evident forensic ledger. You are always ready for an AUSTRAC review or independent audit.
Generate Suspicious Matter Reports (SMRs) and the supporting records for your annual compliance report and independent reviews directly from within ClearAML.
ClearAML’s built-in training modules help your staff meet their annual CPD and CLE obligations on AML compliance — keeping your practising certificates safe at no additional cost.

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Frequently asked questions

Yes. ClearAML meets ARNECC standards for digital Verification of Identity (VOI), providing the “reasonable steps” required for electronic conveyancing under the Model Participation Rules.
Yes. The biometric liveness checks and DVS integration meet ARNECC’s digital VOI standards, making ClearAML suitable for both legal intake and conveyancing settlements.
Yes. ClearAML provides a tax invoice for every check so you can list the AML/VOI check as a standard disbursement on your final bill.
Practice management system integrations are on the development roadmap. Foundation members can vote on which system ClearAML connects with first.
Yes. All data is encrypted at rest and in transit using bank-grade 256-bit encryption. ClearAML hosts exclusively in Australian data centres to ensure data sovereignty.