Legal practices · Table 6, professional services
Last checked 25 September 2026 against the AML/CTF Act compilation C2026C00274, the AML/CTF Rules 2025 (F2025L01026) and the Transitional Rules 2026 (F2026L00393)
Conveyancing, setting up companies and trusts, and holding client money for a transaction bring most small law practices into Table 6. Litigation on its own generally does not. If your practice provides a Table 6 service, it has had AML/CTF obligations since 1 July 2026.
s 6 Sch 3 item 11 AUSTRAC professional designated services
Not sure your practice is regulated? Work through our questions, or use AUSTRAC's tool (AUSTRAC website, opens in a new window).
AUSTRAC's legal profession starter kit is free
AUSTRAC publishes a free program starter kit for legal practices. If your practice fits AUSTRAC's profile and you have time to customise it, it may be all you need. Our legal practice edition is built on it, openly and with attribution.
AUSTRAC's legal profession starter kit (AUSTRAC website, opens in a new window)
01 Scope
Table 6 in section 6 of the Act lists the professional services that are designated. These are the items a small law practice is most likely to provide. The summary is ours; the wording of the Act decides.
| Item | The service, in short | Your customer | Legal example |
|---|---|---|---|
| 1 | Assisting a person to plan or carry out a transaction to sell, buy or otherwise transfer real estate, or acting for them in it, other than under a court or tribunal order | Your client | Conveyancing |
| 2 | Assisting in a transaction to sell, buy or transfer a company, trust or other body corporate or legal arrangement | Your client | Acting on a share sale or business sale |
| 3 | Receiving, holding and controlling (including disbursing), or managing, a client's money or property as part of a transaction, unless section 6(5C) applies | Your client | Trust-account money you control for a client's transaction |
| 4 | Assisting in equity or debt financing for a company, trust or other body corporate or legal arrangement | Your client | Drafting finance documents for a client company |
| 6 | Assisting to create or restructure a company, trust or other body corporate or legal arrangement | Your client, plus a new company's beneficial owners and directors, or a new express trust's trustee, settlor and beneficiaries | Preparing a company constitution or a discretionary trust deed |
| 7 and 8 | Acting as, or arranging for someone to act as, a company director or secretary, a partner, a trustee of an express trust or a power of attorney of a body corporate or legal arrangement (item 7), or a nominee shareholder (item 8) | The person you act for (the nominator) | Acting as trustee of a client's express trust |
| 9 | Providing a registered office or principal place of business address | The person you provide it to | Your office as a client company's registered office |
s 6 s 6(5C) AUSTRAC professional designated services
Not designated, in AUSTRAC's guidance or the Act: litigation generally, because in AUSTRAC's view it does not directly advance a transaction and usually concerns things that have already happened; advice that only influences a transaction, such as advising a conveyancer on the legal effect of contract terms; drafting a will and the testamentary trust it creates, which AUSTRAC says fall outside items 2 and 4 to 9; and a barrister's work on a solicitor's instructions given in connection with a designated service. s 6(6B) AUSTRAC professional designated services
You decide, and you write the decision down
Whether a service is designated is your practice's decision, made on the Act and AUSTRAC's guidance. Use AUSTRAC's Check if you may be regulated tool (opens in a new window), keep the result, and record your decision service by service. Documents 01 and 29 of the legal practice edition are built for that record.
02 Where practices get caught out
A suspicious matter report is normally due within 3 business days of forming the suspicion, or 24 hours for terrorism financing. Where you reasonably believe some, but not all, of the information is privileged, the report goes with an LPP form, and where that privilege may belong to someone other than your practice, the clock is 5 business days. Where you reasonably believe all of the grounds are privileged, you may refuse to report. Since 1 July 2026, legal professional privilege in the Act includes privilege under Division 1 of Part 3.10 of the Evidence Act 1995. s 41 s 41(2A) s 5 Sch 4
An LPP form is also needed when you withhold privileged material from a threshold transaction report, from program documents AUSTRAC asks for, from further information after a report, and from answers to section 167 and section 202 notices. Each of those is a civil penalty provision. s 26Q s 43 s 49 s 167 s 202
Section 123(4) lets a legal practitioner, or a law practice, disclose in good faith to dissuade a client from conduct that is, or could be, an offence. Outside that exception, disclosing that a suspicious matter report has been or must be made, where that would or could reasonably be expected to prejudice an investigation, is an offence: up to 2 years' imprisonment or 120 penalty units, or both. Your policies must include safeguards against tipping off. s 123 Rules 5-13
In AUSTRAC's example, a litigation practice holding settlement money in escrow is likely to fall within the exclusion in section 6(5C)(b), because the money is reasonably incidental to a service that is not designated. That exclusion only works if the practice provides no other designated service, counted across all its practice areas. Once you also do conveyancing or company work, you have to decide afresh whether holding that money is item 3. s 6(5C) AUSTRAC professional designated services
03 The legal practice edition
The edition holds the 25 program documents every edition has: the risk assessment, the policies, the process document, client due diligence (CDD) forms, registers and the reporting calendar. The kit page lists them all. The legal wording runs through them: the policies carry the privilege and retainer-termination clauses, and the escalation and reporting documents add the privilege screening step, the 5-business-day clock and an LPP form column. Then come four documents of its own:
Who assesses privilege, the 5-business-day clock, the right to refuse where all the grounds are privileged, every other place an LPP form is needed, and a register of each form given.
What personnel may say, the good-faith exception for legal practitioners, ending a retainer without tipping off, and the record of each decision.
The second set of client forms and second risk assessment for practices that conveyance, with the delayed-check window for buyer clients and the request to verify information form.
Records which personnel act under a practising certificate, the barrister carve-out, and why the legal profession kit, not the conveyancer kit, applies.
AUSTRAC's original files are not in our zip. You can download them free from AUSTRAC's legal profession kit document library (opens in a new window) and compare them with ours.
Built for the practices AUSTRAC's kit was built for
AUSTRAC designed its legal profession kit for practices that only provide professional designated services, have 15 or fewer personnel (counting administrative staff), have some or all of those providing designated services under a practising certificate, mostly deal with individual clients who are Australian residents, do not regularly deal with high-risk clients or overseas property, offer no fully remote self-service, do not sell property they own, are not acquiring another practice or its clients, and are not part of a large reporting group, foreign branch or subsidiary. AUSTRAC says the kit can be adapted to mixed practices that do both conveyancing and commercial work. Outside the profile, AUSTRAC says you "cannot rely on the starter kit to meet AUSTRAC's regulatory expectations". The same goes for our edition, which is built on it. AUSTRAC legal profession kit: getting started
04 What the law requires
| Obligation | In short | Law |
|---|---|---|
| Enrolment | Enrol on AUSTRAC's Reporting Entities Roll. You apply directly to AUSTRAC; you do not need us for it. | s 51B |
| AML/CTF program | A written ML/TF risk assessment and AML/CTF policies, documented before your first designated service and approved by a senior manager | s 26B s 26C s 26F s 26P Rules 5-15 |
| Compliance officer | A person at management level who is a resident of Australia and fit and proper, designated within 28 days of your first designated service; AUSTRAC told within 14 days. A sole practitioner can be the governing body, the senior manager and the compliance officer, and then does not report to themselves. | s 26J s 26K s 26M Rules 5-7 AUSTRAC sole traders and micro businesses |
| Client checks | Who the client is, their beneficial owners, politically exposed person and sanctions status, and the purpose of the work, before you act unless the Rules allow a delay (such as the window for a conveyancing buyer); then ongoing checks | s 28 s 29 s 30 |
| Reports | Suspicious matters within 3 business days (5 where a third party's privilege may cover part of the information; 24 hours for terrorism financing); physical currency of A$10,000 or more within 10 business days | s 41 s 43 |
| Records | Kept for 7 years | s 107 s 111 s 116 |
05 Key dates
Program, client due diligence, reporting and record-keeping obligations began for professional services (Table 6). The Act's legal professional privilege changes commenced the same day.
Enrolment was due for practices already providing a Table 6 service on 1 July 2026. A practice that starts later has 28 days from its first designated service. A missed date does not end the obligation: it continues until you enrol.
Not enrolled yet? You enrol directly with AUSTRAC. You do not need to buy anything from us to do it. Enrol with AUSTRAC (opens in a new window)
AUSTRAC said it had begun issuing section 167 notices to businesses that appear to be providing designated services but have not enrolled. It named lawyers among them.
Your first annual compliance-report period ends.
Last day to lodge your first annual compliance report.
First independent evaluation, if you were in the 29 July 2026 enrolment group: before 30 June 2029, 31 December 2029, 30 June 2030 or 31 December 2030, depending on the last two digits of your enrolment identifier.
As at 17 September 2026, AUSTRAC's enrolment table listed 6,580 lawyer enrolments. AUSTRAC Enrol with us overview
06 Done for you
You pay once, download the full kit straight away, and receive the legal practices intake questionnaire. We send your draft documents within 5 business days of receiving your complete intake. Privilege handling is included in every band.
Band 1 · 1–3 personnel
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A sole practitioner or a practice of 1 to 3 personnel, one office.
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Band 2 · 4–8 personnel
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Band 3 · 9–15 personnel or mixed service lines
A$2,490 one-off, includes GST of A$226.36
9 to 15 personnel, two offices, or a practice doing both conveyancing and commercial work.
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We are not a law practice and do not give legal advice. We do not act as your compliance officer, lodge reports for you or carry out your independent evaluation. If your intake shows your practice is outside AUSTRAC's starter-kit profile or has more than 15 personnel, we tell you and refund you in full before any work starts. Full Setup details · All prices
07 Straight answers
The Table 6 items a law practice most often provides are: real estate transactions (item 1); the sale or transfer of a company or trust (item 2); receiving, holding or managing client money as part of a transaction, unless section 6(5C) applies (item 3); equity or debt financing (item 4); creating or restructuring a company or trust (item 6); acting as, or arranging, a director, secretary, trustee or nominee shareholder (items 7 and 8); and a registered office address (item 9). Litigation generally is not, nor is a barrister's work on a solicitor's instructions given in connection with a designated service. s 6 s 6(5C) s 6(6B)
Where you reasonably believe some, but not all, of the information required in the report is privileged, the report must be accompanied by an LPP form. Where that privilege may belong to someone other than your practice, the report is due within 5 business days instead of 3. Where you reasonably believe all of the information that forms the grounds for the suspicion is privileged, you may refuse to give the report. Terrorism-financing suspicions stay at 24 hours. s 41 s 41(2A)
Five other places: when AUSTRAC asks for your program documents (section 26Q(2A)), in threshold transaction reports (section 43(3)(aa)), when you are asked for further information after a report (section 49(4)), and in answer to notices under sections 167(5) and 202(5). Each is a civil penalty provision. Document 26 of the legal practice edition lists them and keeps a register of every LPP form you give. s 26Q s 43 s 49 s 167 s 202
Section 123(4) lets a legal practitioner, or a law practice, disclose in good faith to dissuade a client from conduct that is, or could be, an offence. Otherwise, disclosing that a suspicious matter report has been or must be made is an offence where it would or could reasonably be expected to prejudice an investigation. If you rely on the exception, you carry the burden of pointing to evidence for it, so record what you said and why. Document 27 of the legal practice edition covers ending a retainer, adapted from AUSTRAC's legal profession policy. s 123 Rules 5-13
A sole practitioner or a practice of 1 to 3 personnel: Band 1. A practice of 4 to 8 personnel: Band 2. A practice doing both conveyancing and commercial work, which needs two risk assessments and two sets of client forms, two offices, or 9 to 15 personnel: Band 3. Privilege handling is included in every band. If you are unsure, email [email protected] with your headcount and services before you pay.
No. We are not a law practice. The documents adapt AUSTRAC's legal profession starter kit, with each citation checked against the Act and the Rules. Deciding which of your services are designated, and how privilege applies to a matter, stays with you.
More detail: AML/CTF guides and the sources we rely on.
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