Geographical link to Australia: overseas clients, local firm

People search “AML geographical link Australia” when a two-partner firm assumes an overseas address on the client takes the matter outside AUSTRAC. Checked against AUSTRAC’s page on who and what it regulates on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. How designated services are grouped is AML/CTF designated services. The decision aid is the Tranche 2 decision tree. The sector map is /tranche-2.

The client’s address is not the link

Lawyers meet the geographical-link question when the client is in another country and the work feels international, and the regime asks whether the designated service has a link to Australia. A client’s overseas home does not answer that by itself, in either direction. A firm established here, doing the work here, on an Australian transaction, still reads the test. This page does not reproduce AUSTRAC’s regulation page and does not recite the limbs of the test as if a blog could apply them.

The other file is the one this page is not. A practice with no office in Australia, advising a foreign client on a foreign transaction, is not saved by this article and is not condemned by it. You read the test against where the service is provided. The two-partner firm in Australia does not get to skip that reading because the engagement letter uses a foreign address.

• Start from where the service is provided. The firm’s Australian office is the fact. The client’s passport country is a customer fact, not a substitute.
• An Australian transaction keeps the question alive. Buying Australian land, or arranging an Australian deal, is why the overseas client called a local firm.
• Do not opt out from the address block. Write down why you think the link is present or absent, after you have read the AUSTRAC material.
• Customer due diligence follows the in-scope service. If the service stays in, the program’s KYC or KYB step stays in. The client can be overseas and still be the person who completes the check.

Local firm, overseas client

Checks in a law practice generally are AML checks for lawyers. This page stays with the geographical link.

Where the geographical-link page stops

This page is the local firm with an overseas client. It is not a determination of the statutory test and it is not the foreign-firm page. FreeAML does not decide that your matter is linked to Australia.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. An overseas address does not move the list price, and a check the program requires is still client-pays. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that your matter has a geographical link to Australia.

Frequently Asked Questions