Holding client funds in a legal trust account and AML

People search “trust account AML CDD trigger” when a law firm treats every trust receipt as proof that customer due diligence now applies, or treats a quiet receipt as proof that it does not. Checked against AUSTRAC’s professional designated services on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Who files when cash hits a trust account is who files a TTR on trust-account cash. The threshold itself is the threshold transaction report. The sector map is /tranche-2.

The receipt is not the service

Legal trust accounts receive money on matters that are designated services and on matters that are not, and the CDD trigger is the designated service in your program, read against AUSTRAC’s professional designated-services material. This page does not reproduce that material and does not list every legal service that is in or out. A receipt confirms money moved, and it does not classify the work. Trust account AML CDD trigger, said plainly, means you classify the work first.

Cash is the neighbouring mistake, and a cash payment at or above the threshold can require a threshold transaction report even when you are still arguing about the designated service. Do not park that cash in the CDD debate. Do not treat an electronic receipt as a threshold report either, and international transfers have their own report. Each lodgement stays on its own page.

• Classify the matter. Designated service or not, in a sentence on the file, before you talk about the trust ledger.
• Then apply CDD only if it is in scope. Banking the money does not create the duty, and refusing to look at the ledger does not remove a duty that the service already created.
• Pull cash out as its own question. At or above the threshold, open the threshold-report page. Do not hide the cash inside a CDD note.
• Do not use the trust account as a customer list. People who paid money are not automatically the customers of a designated service.

Receipt, service, and a cash report

International funds transfer reports for property-related firms are IFTIs for property firms. Law-firm checks generally are AML checks for lawyers.

Where the trust-account page stops

This page is why a trust receipt is not the CDD trigger. It is not the threshold-report procedure and it is not a list of designated legal services. FreeAML does not classify the matter or lodge a report.

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. A trust receipt is not a KYC fee, and a check is client-pays only when the designated service’s program requires verification. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a trust receipt is a designated service or lodge a threshold report.

Frequently Asked Questions