New Client Verification Requirements from 1 July 2026
From 1 July 2026, new Anti Money Laundering and Counter Terrorism Financing requirements will apply to certain legal services in Australia. Where those requirements apply to a matter, we may need to obtain additional information and documents from clients before we are able to act, and in some cases while a matter is ongoing.
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What this means for clients
These changes do not affect every legal matter in the same way. Whether the new requirements apply will depend on the nature of the work and the circumstances of the matter. For some clients, the process may feel much the same as it always has. For others, there may be a more formal verification and due diligence stage at the beginning of the matter, or further requests for information as the matter progresses.
Important. Where these requirements apply, there may be legal steps that need to be completed before the relevant service can properly proceed.
Why these changes are being introduced
These reforms are being introduced to reduce the risk that legal and other professional services may be used in connection with money laundering, terrorism financing and other serious financial crime. They form part of Australia’s broader legal and regulatory framework and are intended to strengthen the integrity of the legal and financial system.
From a client perspective, that means law practices may now be required, in some regulated matters, to take more formal steps to understand who they are acting for, the structure involved, and the nature of the relevant transaction. This is not simply a change in office procedure or a matter of firm preference. Where the legislation applies, it reflects legal obligations that now attach to certain services commonly provided by lawyers.
When these requirements may apply
These requirements may arise in certain matters involving property transactions, the sale or transfer of a company or other legal arrangement, the creation or restructuring of a company or trust, certain financing arrangements, or the receipt, holding, control or management of money or other property as part of a regulated transaction.
They may also apply in some matters involving particular nominee, trustee, partner, director, secretary or registered office arrangements. Whether a matter falls within the relevant framework will depend on the facts of the case. That is why the level of information required may differ from one matter to another.
What information we may need from clients
The information required will depend on the client and the matter. In some cases, we may ask for proof of identity and proof of address. In others, we may need company, trust or other structure documents, details of directors, trustees, beneficial owners or controlling persons, confirmation of who is authorised to give instructions, and information that helps explain the purpose and structure of the transaction.
In some matters, further information may also be required about the source of funds or other aspects of the transaction background. This will not apply in every case. However, where the circumstances of a matter require a greater level of due diligence, we may need to ask more detailed questions than clients may previously have expected in a legal context.
What happens if the required information is not provided
Where these requirements apply, there may be limits on what we can do until the required information has been provided and, where necessary, verified.
If requested information is not provided promptly, it may affect when we are able to begin work on a regulated matter or progress particular steps within it. If information required by law is not provided at all, we may be unable to provide the relevant legal service.
That is not intended to be punitive. It is simply the practical effect of the legal requirements that now apply in certain matters. In most cases, providing requested information early will help avoid unnecessary delay and allow the matter to proceed more smoothly.
Confidentiality and our professional obligations
We recognise that clients may have understandable concerns about privacy when asked to provide additional personal, structural or transaction information. These requirements operate alongside our existing professional obligations.
Our firm remains committed to handling client information carefully and professionally. Where additional information is required, we will request what is relevant to the matter and explain the purpose of that request as clearly as possible.
The legislation does not affect legal professional privilege. Where issues of privilege arise, they will continue to be considered in accordance with the law.
Frequently Asked Questions
No. Whether these requirements apply will depend on the type of legal service being provided and the circumstances of the matter.
Yes. If relevant circumstances change during the course of a matter, or if further due diligence is required, updated documents or further clarification may need to be requested.
Where these requirements apply, delay in providing information may delay the commencement of the matter or the progress of particular steps. In some circumstances, if required information is not provided, we may be unable to provide the relevant legal service.
These requirements operate alongside our existing professional obligations. The legislation does not affect legal professional privilege, and issues of privilege continue to be considered according to law.