Important Update: AML/CTF Client Onboarding Requirements

Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) laws have expanded to include legal practices that provide certain designated services.

At KCT Legal, we have implemented systems and processes to comply with these requirements while ensuring the process is as efficient and straightforward as possible for our clients.

This article explains what AML/ CTF requirements consists of, the information we may request from you, and how we will guide you through the process.

What has changed?

From 1 July 2026, Australia’s AML/CTF regime applies to legal practices providing certain designated services.

These reforms are intended to strengthen Australia’s ability to detect and prevent money laundering, terrorism financing and other serious financial crimes, while aligning Australia’s regulatory framework with international standards.

As a reporting entity, KCT Legal is required to comply with the AML/CTF requirements administered by AUSTRAC. This includes undertaking client due diligence, understanding the nature and purpose of certain matters, conducting ongoing client due diligence where required and maintaining appropriate records. These are legal obligations imposed on our firm and are not discretionary.

Depending on the legal services we provide, we may be required to:

• verify the identity of our clients and, where applicable, individuals acting on their behalf;

• identify and verify the beneficial owners and controllers of companies, trusts and other entities;

• confirm the authority of persons giving instructions on behalf of another person or entity;

• understand the nature and purpose of the matter or transaction;

• obtain information regarding the source of funds or source of wealth, where required;

• conduct ongoing client due diligence where required; and

• maintain records to comply with legislative requirements.

These obligations may apply to both new and existing clients where designated services are provided, although the timing and extent of verification may differ depending on the nature of the matter and the level of risk involved.

What information may we request?

To meet our legal obligations, we may need to obtain and verify certain information before commencing work, or before continuing to provide certain designated services.

Depending on your circumstances and the nature of the matter, we may request:

• current photo identification, such as a driver licence or passport;

• proof of your current residential address;

• company or business information, including ASIC records where applicable;

• trust deeds, partnership documents or other constituting documents;

• information about directors, shareholders, trustees, appointors, beneficiaries, partners or other relevant controllers;

• information about individuals who ultimately own or control a company, trust or other entity;

• evidence of authority where you are acting on behalf of another person, company, trust or entity;

• information about the nature and purpose of the matter or transaction;

• information or documents relating to the source of funds or source of wealth, where required; and

• any other information reasonably required to satisfy our AML/CTF obligations.

We will only request information that is necessary for us to satisfy our legal and professional obligations.

How does the verification process work?

Where appropriate, identity verification may be completed securely using an electronic verification service. This process is usually straightforward and can often be completed within a short period.

All personal information collected will be handled securely and in accordance with our privacy obligations, professional duties and applicable legislation.

What does this mean for you?

In some circumstances, we may be unable to commence or continue providing certain legal services until the required client due diligence has been completed.

To help avoid delays, we ask that you respond promptly if we contact you requesting identification, verification or supporting documentation.

These checks are routine compliance requirements. A request for information does not mean that we have any concern about you, your matter or your transaction. It simply reflects the obligations now imposed on legal practices under the AML/CTF regime.

Ongoing requirements

AML/CTF compliance is not limited to the beginning of a matter. In some cases, we may be required to update or refresh client information during the course of a matter, particularly where there is a material change in instructions, parties, ownership, funding arrangements, transaction structure or risk profile.

This may include requesting updated identification, further information about beneficial ownership or control and additional information about the source of funds or source of wealth relevant to a transaction.

We’re here to help

We appreciate your cooperation as we implement these legislative requirements. Our team has established appropriate systems, processes and procedures to meet our obligations while continuing to provide a high level of service with minimal disruption to our clients.

If you have any questions about these changes or the information we request, please do not hesitate to reach out to our team.