Aspects of the legal profession are identified as being attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

Why will the legal profession have AML/CTF obligations?

Legal practitioners and conveyancers provide services that operate as a gateway to property and financial markets, financial institutions and other regulated professionals.

These ‘gatekeepers’ provide financial and business services that can be abused to disguise beneficial ownership, conceal the origins and purposes of financial transactions, facilitate tax evasion and, ultimately, launder the proceeds of crime. Operating through or behind a professional adviser can provide a veneer of legitimacy to criminal activity.

Legal practitioners can be used to create complex (but legal) structures that can create distance between criminals and their illicit wealth. Conveyancers facilitate a process that allows for the transfer of ownership of property, a high-value asset that provides ideal opportunities for laundering large volumes of illicit funds.

What are the ML/TF risks faced by the legal profession?

The Money Laundering and Terrorist Financing (ML/TF) risks associated with the legal profession include:

  • Obscuring ultimate ownership through complex layers and legal entity structures
  • Evading tax and exploiting known tax shelters
  • Evading regulatory controls
  • Providing a veneer of legitimacy to criminal activity
  • Creating distance between criminal entities and their illicit income or wealth by using complex business and corporate structures
  • Avoiding the detection and confiscation of assets, and hindering law enforcement investigations


Legal practitioners must ensure they conduct a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures. This is a critical first step in AML/CTF compliance.

What services may be covered by AML/CTF obligations?

These are the services offered by lawyers and conveyancers that may be included as designated services under the AML/CTF Act.

  • Acting as a formation agent of legal persons or legal arrangements
  • Acting as, or arranging for a person to act as, a nominee director or nominee shareholder or trustee in relation to legal persons or legal arrangements
  • Providing a registered office or a business address, a correspondence address, or an administrative address for a company, or a partnership, or for any other legal person or arrangement
  • Managing client funds (other than sums paid as fees for professional services), accounts, securities, or other assets
  • Engaging in a transaction on behalf of any person in relation to the buying, transferring, or selling of a business or legal person (for example, a company) and any other legal arrangement
  • Engaging in a transaction on behalf of a customer in relation to creating, operating, and managing a legal person (for example, a company) and any other legal arrangement
  • Engaging in or giving instructions on behalf of a customer to another person for any conveyancing to affect the grant, sale, or purchase or any other disposal or acquisition of real estate or an interest in land
  • The transfer of a beneficial interest in land or other real property
    If you offer or provide one or more of the above services, your business will be subject to AML/CTF obligations.
What is a risk-based AML/CTF regime?

The AML/CTF regime is risk-based, which means that your responses to the AML/CTF obligations placed upon you should be risk-based. 

A risk-based AML/CTF regime requires that you understand and address the Money Laundering and Terrorism Financing (ML/TF) risks associated with the legal services you offer.

You must then design, implement and maintain systems, procedures and controls that appropriately manage and mitigate your ML/TF risks.

How can Initialism help?

Initialism are the AML/CTF experts, so you don’t have to be.

With over 50 years of expert knowledge and real world experience our AML/CTF compliance solutions will to help you navigate your legal and regulatory requirements so that your business complies with its AML/CTF obligations in the fastest and most cost-effective way.

Initialism has a range of AML/CTF Program solutions to support your business in becoming AML/CFT compliant and maintaining compliance.

AML/CTF compliance solutions for
your legal practice

Initialism is the only AML/CTF consultancy in Australia to have supported Legal Professionals complying with AML/CTF obligations. Our AML/CTF compliance solutions for legal professionals draw on unparalleled expertise, knowledge and real-world experience.

Why choose Initialism?


Our expertise covers all AML/CTF disciplines and brings unique perspectives, approaches and solutions to the AML/CTF challenges faced by the legal profession


Our AML/CTF compliance knowledge includes working with legal firms and we understand what compliance means for your legal practice


We have experience in delivering workable AML/CTF compliance to legal practices, each with their own unique challenges


Our knowledge and expertise has been hard earned and comes from working in the area of AML/CTF for many decades


We have experience in providing tried and tested AML/CTF solutions, regardless of the size and complexity of your legal practice


Our AML/CTF compliance solutions are flexible and can be tailored to your capacity, experience and budget



Initialism are the industry leading experts in anti-money laundering compliance. Our AML compliance consultants bring decades of experience helping businesses meet their obligations. Together with our AML compliance solutions we offer a range of additional financial crime risk management services to help Australian reporting entities, including AML/CTF Independent Review and AML/CTF Training.