Guides · Updated 24 Sept 2026

AML/CTF and the law firm trust account

Your trust account is regulated by the legal profession rules and, from 1 July 2026, by the AML/CTF Act as well. The two overlap but are not the same.

A bound trust deed with a navy cover and ribbon on a walnut desk, beside reading glasses.

What changes

  • Money received into trust in connection with a designated service is part of that service. Money held only for payments incidental to non-designated work, such as litigation settlement funds, and payments to courts, the ATO or insurers are excluded.
  • Physical cash of AU$10,000 or more received into trust triggers a threshold transaction report within 10 business days.
  • Unusual movements through trust are a classic trigger for a suspicious matter report.

What does not change

Trust account rules, external examinations and receipting continue as before. AML records sit alongside them.

Practical policy

Most small firms decide not to accept cash of AU$10,000 or more, state it in the program and never lodge a TTR.

Questions people ask

Does the trust account examiner check AML?
The external examination is a legal profession requirement. AUSTRAC is the AML regulator. Keep both sets of records complete.

Sources

Official AUSTRAC guidance this page was checked against. The date is when we captured the page; AUSTRAC may have updated it since.

This guide is general information for solicitors, conveyancers, settlement agents, not legal advice. Check AUSTRAC's current guidance for your situation.

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AML/CTF and the law firm trust account · PracticeAML