Updates to the legal profession program starter kit

AUSTRAC has released an updated version of the legal profession program starter kit, the template document small and low complexity law practices can adopt and customise as their anti-money laundering and counter-terrorism financing program under the reformed regime. The most recent release, version 1.1, published in June 2026, changes several aspects of the kit, including extending the delayed customer due diligence timeframe for conveyancing services provided to buyers from 15 days to 28 days after exchange of contracts or 3 days before settlement, clarifying when beneficial ownership checks can stop for certain customer types, moving annual compliance reporting from a calendar year to a financial year basis, and clarifying that indicators of unusual or criminal behaviour apply from initial customer onboarding.

AUSTRAC classifies updates by their significance, distinguishing minor corrections from meaningful additions and from major changes affecting structure or workflow. The June 2026 release is classified as a minor update. Practices that have customised the starter kit to build their own program are expected to review each update and decide whether it should be incorporated, rather than having the change applied automatically.

The starter kit update follows the commencement of AML/CTF obligations for newly regulated sectors, including legal services, from 1 July 2026. It is relevant to law practices, including conveyancing practices, that rely on the starter kit as the basis of their compliance program, and to any practice assessing whether its existing program reflects the current due diligence and reporting timeframes.