Compliance Update · July 2026
AML/CTF Changes 2026: Your Questions Answered
From 1 July 2026, new federal laws require us to verify your identity before providing certain legal services. Here's exactly what's changing, what it means for you, and, importantly, why existing clients don't need to do anything right now.
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On 1 July 2026, the Anti-Money Laundering and Counter-Terrorism Financing Act extended what are known as 'Tranche 2' obligations to legal practices across Australia. These reforms bring Australian law firms into line with international standards set by the Financial Action Task Force (FATF) - making Australia one of the last OECD countries to take this step.
Here's what it means for you and your relationship with Farrell Goode.
Why Is This Happening?
Money laundering and financial crime frequently exploit the professions that sit at the gateway to major transactions - lawyers, conveyancers, accountants, and real estate agents are commonly used (often unknowingly) to move and conceal criminal proceeds through property purchases, trust structures, and business dealings. The Tranche 2 reforms close that gap, extending Know Your Client (KYC) obligations to legal practices. AUSTRAC, Australia's financial intelligence agency, is overseeing implementation.
Importantly, the new laws regulate what we do, not who we are. Only specific types of legal work - called designated services - trigger the requirements.
Which Legal Services Are Affected?
Not all legal work is caught. The obligations apply specifically to 'designated services' - those involving property, money movement, or legal structures:
- Buying, selling or transferring real estate - residential, rural, or commercial conveyancing
- Buying or selling a business
- Setting up, restructuring or winding up companies, trusts, or partnerships
- Receiving, holding or managing your money or property in connection with a transaction (beyond payment of our legal fees)
- Acting as (or arranging) a nominee director, shareholder, or trustee
- Providing a registered office or business address
✅ Court representation, criminal and traffic matters, family law advice, and preparing your will or power of attorney are NOT designated services. Those continue exactly as they do now - no interruption, no new requirements. (If a matter later involves transferring property or setting up an entity - for example, selling a home in a deceased estate - the verification step applies to that part of the work.)
If You're an Existing Client - What 'Pre-Commencement' Means
🛡️ No immediate action required for existing clients
If you were already a client of Farrell Goode before 1 July 2026, you are classified as a 'pre-commencement client' under the legislation. This means we are not required to verify your identity on 1 July. The verification requirement applies the next time you engage us for a designated service - not before.
In practical terms: if you come to us in August to sell a property, or in October to purchase a business, that is when we will ask for identity documents - before we begin that specific matter. Any other legal work is completely unaffected.
If You're a New Client
If you are engaging Farrell Goode for the first time after 1 July 2026, identity verification is required before we can commence any designated service. We will provide you with a personalised checklist of exactly what's needed - the process typically takes a matter of days, and we'll build it into your matter timeline so nothing is delayed.
What the Verification Process Looks Like
When the time comes, we'll ask for identity documents suited to your situation:
- 🪪 Individuals - current passport and driver's licence
- 🏢 Companies - ASIC extract plus ID for each director and beneficial owner
- 📄 Trusts - certified copy of the trust deed plus trustee and beneficiary IDs
- 🤝 Partnerships - partnership agreement plus partner IDs
- ⚖️ Deceased estates - ID for the executor or administrator, plus the grant of probate or letters of administration where applicable
We'll provide a personalised checklist and most clients are through the process within a few days.
What Happens to Your Information?
Your documents are handled with the same strict confidentiality that applies to everything you share with your solicitor. They are used only for identity verification purposes and retained for the minimum period required by law. We do not sell or misuse your personal information - and the new laws expressly preserve legal professional privilege, so confidential legal advice remains protected.
What Should You Do Right Now?
If you are an existing client - nothing. We will contact you when a designated service triggers the requirement. If you have a transaction on the horizon (a property sale or purchase, a business sale, a new trust or company), simply be aware the verification step is coming so it doesn't delay your settlement or completion date.
If you have questions, please get in touch with any of our five offices. We are committed to making this as straightforward as possible.
Frequently Asked Questions
The questions we hear most from clients about the new AML/CTF requirements.
+ Why are you asking for my passport and driver's licence?
Under the new AML/CTF laws, we are legally required to verify the identity of every client before providing certain services. Government-issued photo ID - your passport and driver's licence - is the most straightforward way to do that, because it confirms both your identity and your face.
If you've bought or sold property before, this will feel familiar - identity verification has long been part of conveyancing. The new laws extend a similar requirement to a broader range of legal work, and it's the same requirement you'd encounter at a bank or financial planner. We treat your documents with the same strict confidentiality as everything else you share with us.
+ Why is Farrell Goode asking for my identity documents now, when we've been working together for years?
New federal legislation, the AML/CTF Act, requires us to formally verify client identities before providing certain designated services. Because you are an existing client, we were not required to do this on 1 July 2026. The requirement applies now because you have engaged us for a matter that triggers it. We are not singling you out - this applies to all clients when they request this type of work.
+ Does this mean Farrell Goode suspects me of something?
Absolutely not. Identity verification is required for every client without exception, regardless of history or relationship. It is simply the law, and it applies uniformly across our entire client base - exactly as it does at banks, accountants, and financial planners.
+ What services trigger these checks?
The checks apply when Farrell Goode assists with buying, selling or transferring real estate; buying or selling a business; setting up, restructuring or winding up companies, trusts or partnerships; holding or managing client money or property in connection with a transaction; providing a registered office address; or acting as a nominee director, shareholder or trustee.
Court representation, criminal and traffic matters, family law advice, and preparing your will or power of attorney are not affected.
+ Will I need to do this every time I engage Farrell Goode?
Once verified, your details stay on file. As part of our ongoing obligations we refresh verification periodically, generally every 2 years, or sooner if your circumstances change, such as new entities or changes to ownership or control.
+ What documents do I need to provide?
It depends on your structure. In general:
- Individuals - current passport and driver's licence
- Companies - ASIC extract plus director and beneficial owner IDs
- Trusts - certified copy of trust deed plus trustee and beneficiary IDs
- Partnerships - partnership agreement plus partner IDs
- Deceased estates - executor or administrator ID, plus the grant of probate or letters of administration where applicable
We'll send you a personalised checklist when the time comes.
+ Will this delay my property settlement?
Not if verification is completed early - and we make sure it is. Identity verification is one of the first steps in your matter, completed well before contracts are exchanged or settlement is booked. The process itself usually takes only a few days. The only situation where delays arise is when documents are missing or incomplete, which is why we ask for everything up front.
+ Does this affect legal professional privilege or the confidentiality of my legal advice?
No. The AML/CTF Act expressly preserves legal professional privilege. The confidential legal advice we give you, and the communications between you and your solicitor, remain protected exactly as they always have been. The new requirements relate to verifying who you are before certain transactions - not to the content of your legal advice.
+ Is my information kept confidential?
Yes. Your privacy is protected at every step. Farrell Goode does retain copies of your identity documents for 7 years as required by legislation.
We do not share your information with third parties except as required by law.
+ Who is InfoTrack and why is Farrell Goode using them?
InfoTrack is one of Australia's leading legal technology platforms, used daily by thousands of law firms and conveyancers across the country. They are not a new or unknown company - they have been operating in the Australian legal sector for over 20 years and are widely regarded as the industry standard for identity verification and due diligence in legal practice.
We use InfoTrack's identity verification product - InfoTrackID - because it allows identity documents to be verified securely. This protects your privacy while satisfying our legal obligations under the AML/CTF Act. InfoTrackID verifies documents against the Australian Government's Document Verification Service (DVS), which means the check is authoritative and government-backed.
+ What does InfoTrack do with the identity documents I provide?
When you complete the InfoTrackID verification process, your documents are checked against the Australian Government's Document Verification Service (DVS) within InfoTrack's secure system. The documents are used solely to confirm your identity - nothing else.
InfoTrack retains your identity documents and personal information within their secure platform for 90 days only, after which everything is permanently and irreversibly deleted. They do not sell, share, or use your information for any other purpose.
For verifications completed through InfoTrackID, Farrell Goode receives the verification report - confirming your identity was verified, when, and by what method - which is retained for 7 years as required by the AML/CTF Act.
+ Is the InfoTrackID process safe? Can I trust it?
Yes. InfoTrack operates enterprise-grade security infrastructure with onshore data storage - meaning your information never leaves Australia. Their platform is compliant with the Privacy Act 1988 and the Australian Privacy Principles, and it is independently audited.
InfoTrackID is the same platform used by thousands of Australian law firms and conveyancers to verify client identities for property transactions - it is well-established, widely trusted, and purpose-built for exactly this type of sensitive verification work. You can review InfoTrack's Security and Legislation Compliance at any time.
+ Does Farrell Goode keep copies of my identity documents?
Yes - copies are retained by Farrell Goode, pursuant to our Privacy Policy which can be reviewed here. If you verify your documents through InfoTrack, your actual documents remain within InfoTrack's secure system and are permanently deleted after 90 days.
+ Can I complete the verification in person instead of online?
Yes. InfoTrackID supports both remote verification (online, at a time that suits you) and in-person verification at any of our five offices - Temora, Narrandera, Leeton, Cootamundra, or West Wyalong. If you would prefer to complete the process face-to-face, please let us know and we will arrange that with you. Either way, the same privacy protections apply.
+ I've already done a Verification of Identity for a property transaction - is this the same thing?
They're related, but not identical. Verification of Identity (VOI) for conveyancing has been standard practice for some years and confirms who you are for the purposes of a property transfer. The new AML/CTF requirements are broader - depending on your structure, they may also require us to identify beneficial owners, sight trust deeds or company records, and keep verification records for 7 years. In many cases the two can be completed together in a single step, so you won't notice much difference.
+ What if I can't provide all the documents?
Please contact us as soon as possible. We cannot begin work until verification is complete, so resolving any gaps promptly avoids delays to your matter. Alternative documents may be acceptable in some circumstances - just ask us.
+ My trust was set up 20 years ago and I can't find the trust deed - what do I do?
This is more common than you might think, and it's worth sorting out now rather than when you need us to act on the trust. We cannot complete identity verification for a trust without sighting the trust deed - it is required to confirm the trust structure, trustee powers, and beneficial ownership.
If your deed is missing, start by checking with the solicitor or accountant who set up the trust - they may have a copy. If it was set up through a document provider, a replacement certified copy may be obtainable. In some cases a formal deed of confirmation may be needed - something we can assist with. Please contact us as early as possible so we have time to resolve it before it delays a transaction.
+ What happens if Farrell Goode reports something to AUSTRAC?
We are required to report certain transactions and suspicious matters to AUSTRAC. If we make such a report, we are legally prohibited from informing you - this is called the 'tipping-off' rule under the AML/CTF Act. This is standard across all legal, accounting and financial services in Australia, not unique to Farrell Goode. Legal professional privilege is preserved - genuinely privileged communications remain protected.
Have questions?
We're here to help.
Reach out to your nearest Farrell Goode office to discuss how the new AML requirements apply to your situation.
Contact Us →
Temora 02 6977 1155 · Narrandera 02 6959 2288 · Leeton 02 6953 3333
Cootamundra 02 6942 1377 · West Wyalong 02 6972 1155 · farrellgoode.com.au
Further information: This article has been prepared for general information purposes based on AUSTRAC's published guidance, including the Legal Profession Program Starter Kit, the Law Society of NSW's AML/CTF resources, and the AML/CTF Amendment Act 2024. It is general information only and not legal advice about your specific circumstances. For general public information on identity verification requirements, visit austrac.gov.au.