Solicitors no longer have cash reporting obligations under the Financial Transaction Reports Act 1988 (FTR Act). However, changes that commence on 31 March 2026 will place significant new obligations on law firms for initial and ongoing AML/CTF due diligence.
The FTR Act was entirely repealed with effect from 7 January 2025 by Schedule 11 of the Anti-Money Laundering and Counter-Terrorism Financing (Amendment) Act 2024 (the Amending Act).
The Amending Act substantially amends the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) to place new obligations on lawyers who perform certain work as reporting entities. However, the relevant amendments to the AML/CTF Act do not commence until 31 March 2026.
From 7 January 2025 solicitors are no longer regulated under the FTR Act, and do not need to report significant cash transactions of $10,000 or more, or the equivalent in foreign currency, to AUSTRAC. See AUSTRAC’s webpage Repeal of the Financial Transaction Reports Act 1988 for more information.
In the interim, solicitors still have professional obligations that can in some circumstances require cash reporting. See the The Law Council of Australia’s National Legal Profession Anti-Money Laundering & Counter-Terrorism Financing Guidance Note 2 for more information.
The By Lawyers Practice Management publication has been updated in line with the repeal of the FTR Act.
The changes that commence on 31 March 2026 will be significant for most law firms, with new due diligence and reporting obligations. By Lawyers will be updating our publications with information and guidance about these requirements when they commence.
Professional bodies for lawyers and conveyancers around the country already have substantial information available about these changes on their websites. Practitioners can expect professional legal education providers to focus on the topic in the coming 12 months, and legal software providers such as LEAP to provide efficient application-based solutions.