From 1 July 2026, Australia’s Anti-Money Laundering and Counter-Terrorism Financing regime will expand to cover a broader range of professional services and business activities.
For many clients, this may sound like another regulatory change sitting somewhere in the background.
It is not.
These reforms are part of a wider shift in the way businesses, advisers and professional service providers are expected to manage financial crime risk, client verification, source of funds enquiries, ownership structures and transaction transparency.
For businesses, the practical impact may be simple but significant: more checks, more questions, more documentation and greater scrutiny before certain transactions or services can proceed.
Handled poorly, this can create delay, frustration and uncertainty.
Handled well, it can become a competitive advantage.
What is changing?
Australia’s AML/CTF laws are being expanded to capture a wider group of “gatekeeper” professions and services. This includes certain activities carried out by legal practitioners, accountants, conveyancers, real estate professionals and trust and company service providers.
The reforms are designed to strengthen Australia’s ability to detect and prevent money laundering, terrorism financing and proliferation financing.
For clients, this means that professional advisers may be required to take additional steps before, during or after a matter. These steps may include verifying identity, understanding the source of funds or source of wealth, confirming beneficial ownership or control, assessing transaction risk and maintaining appropriate records.
In practice, this may affect matters involving property transactions, corporate structuring, business sales, trusts, companies, asset transfers, investment activity, finance arrangements and other transactions involving movement of funds or valuable assets.
Why this matters for clients
The biggest issue will not simply be compliance.
It will be friction.
Clients are already dealing with a more complex commercial environment: rising cyber risk, increased fraud, tighter lending conditions, more regulatory oversight, global uncertainty, tax scrutiny, privacy obligations and growing pressure to move quickly.
AML/CTF reform adds another layer.
That means businesses need to think ahead. A transaction that previously moved quickly may now require additional information before advisers can proceed. A corporate structure that was once accepted at face value may require further explanation. A source of funds enquiry may need supporting documents. A trust, company or offshore ownership arrangement may need to be reviewed more carefully.
This does not mean clients should be alarmed.
It does mean they should be prepared.
The opportunity: better governance, smoother transactions and stronger trust
While these reforms introduce new obligations, they also create an opportunity for businesses to lift the quality of their governance and reduce future transaction risk.
Businesses that prepare early may be able to:
- reduce delays in property, corporate and commercial transactions
- improve internal record-keeping around ownership and control
- identify gaps in customer, supplier or investor due diligence
- strengthen fraud and financial crime controls
- build confidence with banks, lenders, investors and professional advisers
- respond more quickly when information is requested
- demonstrate that they take compliance and governance seriously
In a market where trust matters, this can be powerful.
Compliance is no longer just a back-office function. It is increasingly part of how businesses protect value, complete transactions, attract capital and maintain confidence with stakeholders.
What clients may be asked for
Depending on the nature of the matter, clients may be asked to provide additional information, such as:
- identification documents
- details of directors, shareholders, trustees or beneficial owners
- information about the source of funds or source of wealth
- documents explaining corporate or trust structures
- information about the purpose and nature of a matter
We understand that this may feel inconvenient, particularly for long-standing clients who are used to a more streamlined process.
Our role is to make this as clear and efficient as possible.
At Madison Marcus, we are preparing our systems, processes and internal guidance so that we can meet our obligations while reducing unnecessary disruption for clients.
Businesses may have their own obligations too
For some clients, the reforms may not only affect how they engage with their lawyers or advisers.
They may also affect their own business.
If your business receives, transfers, manages or deals with funds, property, corporate structures, trusts or high-value assets, it may be worth considering whether the AML/CTF changes apply to you directly or indirectly.
This is particularly relevant for businesses involved in real estate, professional services, accounting, advisory, company and trust services, finance, asset transfers and other transaction-heavy sectors.
The question is not only “will my lawyer ask me for more information?”
The better question is:
“Is my own business ready for the new standard of transparency, verification and compliance?”
The answer often comes down to what your business actually does, not what it calls itself.
The obligations attach to the activity, known as a “designated service”, rather than to a job title or industry label. A business that has never considered itself regulated can still be captured if it provides a designated service connected to Australia.
Where that is the case, the business becomes a reporting entity in its own right. That brings its own obligations, including enrolling with AUSTRAC, appointing a compliance officer, verifying customers and reporting certain matters.
Enrolment is already open and must be completed by 29 July 2026.
If there is any prospect that your business provides a designated service, it is worth confirming your position now, well ahead of the deadline, rather than under pressure.
How Madison Marcus can assist
Madison Marcus is working with clients to help them understand what the AML/CTF reforms may mean for their matters, transactions and businesses.
We can assist with:
- understanding whether the reforms may affect you or your business
- preparing for additional verification and information requirements
- reviewing business, trust and company structures
- advising on transaction readiness before a sale, purchase, transfer or restructure
- supporting businesses that may need to assess their own AML/CTF exposure
- helping clients develop practical governance and compliance processes
- reducing friction before important transactions commence
The aim is not to make compliance more complicated.
The aim is to help clients move through the new environment with confidence.
Preparing early is the advantage
Regulatory change often creates uncertainty at first.
The businesses that wait until a transaction is already underway may face delay, document chasing and avoidable pressure.
The businesses that prepare early can turn compliance into readiness.
If you are planning to buy, sell, transfer, restructure, raise capital, establish a new entity or enter into a significant transaction from mid-2026 onwards, it is worth speaking with us early.
AML/CTF reform is not just a legal change.
It is part of a broader shift towards greater transparency, stronger governance and more accountable professional services.
Madison Marcus is ready to help clients navigate that shift.
Christopher Frankish: Partner, Financial Services & Compliance
Christopher is a highly accomplished financial services lawyer with expertise in governance, regulation, insurance, superannuation and dispute resolution. With over a decade of experience, he has led legal teams and major regulatory projects, including work arising from the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry.
