AML/CTF for small Sydney law firms

7 min readUpdated 21 May 2026By Ben Horne

Not every legal service triggers Tranche 2. The Act picks up specific designated services: assisting in real estate transactions, setting up companies and trusts, managing client money in trust, and certain forms of structuring. From 1 July 2026, small Sydney firms doing any of those have AUSTRAC obligations. Caltury runs the workflow.

The scope test for a Sydney small firm

Litigation, family law, criminal law, employment, immigration and most personal-injury work fall outside the designated services. The work that brings firms into scope is transactional: real estate matters, company and trust formation, structuring, client-money management, certain commercial deal work.

If your firm does any designated service to any client, the whole firm enrols and the whole firm has a Program. The Program describes which engagements trigger AML and which do not. There is no carve-out for firms where designated services are a minority of the practice.

Sydney small-firm patterns

Property-heavy CBD and inner-suburb boutiques are the cohort most clearly in scope. Trust-and-estates practices doing testamentary trust setup and discretionary-trust restructuring are also in scope when the trust formation itself is part of the engagement. Commercial-litigation boutiques may sit outside scope entirely if they do no transactional work.

AUSTRAC has flagged Sydney as a high-risk geography for trust-and-company-service abuse. Small firms providing trust formation as part of a tax-and-estates practice should expect enhanced scrutiny on the beneficial-ownership chain.

How Caltury supports a small law firm

Caltury produces an AML/CTF Program tailored to a small AU law firm rather than a generic template. The customer form branches by entity type and captures beneficial ownership down to the natural person. Sanctions and PEP screening runs at intake and on the cadence the customer's risk band requires. SMR, TTR and IFTI drafts are prepared in AUSTRAC format for the principal to lodge.

Time investment for a 2 to 5 lawyer firm is typically 6 to 10 hours over the 14-day trial. Once live, the ongoing operator load is roughly 15 to 30 minutes per new designated-service engagement plus 15 to 30 minutes when an AUSTRAC report needs to be lodged.

  • Program template specific to an AU small law firm
  • Customer form branched by entity type with beneficial-owner capture
  • Sanctions and PEP screening included on every tier
  • AUSTRAC report drafting in the correct schema
  • Append-only audit log for 7-year retention

Common questions

We are 80 percent family law, 20 percent property. Do we enrol?

Yes. The 20 percent property work is a designated service and the firm enrols as a reporting entity. The Program covers both lines but identifies which engagements trigger AML obligations. The 80 percent family-law engagements do not trigger CDD but the firm-wide records and Program remain in place.

Does the Law Society of NSW act as the AML regulator?

No. The Law Society regulates practising certificates, professional standards and trust accounts. AUSTRAC is the AML/CTF regulator under the Commonwealth Act. The two operate independently. Caltury covers the AUSTRAC side only.

How does Caltury sit alongside our practice management system?

Caltury holds the AML record (Program, customers as AML customers, sanctions screens, AUSTRAC reports, retention vault). The PMS continues to hold the matter file, time recording, billing and trust ledger. Customer data can be imported by CSV; direct API integration is on the roadmap.

What is the cost for a 4-lawyer Sydney boutique?

The Practice tier (A$249/mo plus GST) suits 2 to 5 person firms with a 4-lawyer headcount. The Founding-10 program offers 50 percent off for three years for the first 10 paying customers, bringing the effective price down to roughly A$125 plus GST a month for that period.

This page is general information about Australian AML/CTF obligations. It is not legal advice. AUSTRAC has not reviewed this content. For situations specific to your practice consult an Australian-qualified lawyer or AML/CTF adviser.

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