For property, trust formation, and nominee work, the designated-service trigger is often the trust account. Email your client a FreeAML link before you receipt funds. They pay $20 for a person or $40 for an entity. No subscription. Litigation and advice that never touch client money are usually outside that trigger.
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FreeAML is the full AML suite for the matters that need it: individual KYC, entity KYB, beneficial owners, a CDD report, and ongoing monitoring while funds are held. Your client pays. Your firm can add an optional service charge.
Group verifications by matter reference. Track buyers, sellers, guarantors, and entities for each transaction. See who's verified, who's pending.
Verify clients before accepting funds into trust. Ongoing monitoring while funds are held, with a notification if a later watchlist hit appears. Close the check when the matter ends and the funds are disbursed.
An audit pack for your firm: your program and risk assessment, CDD reports, AUSTRAC reports you prepared, the audit trail, the training register (progress, FAML- certificate IDs when issued in FreeAML, and self-reported device imports), sanctions checks, and annual compliance reports. FreeAML takes reasonable measures to retain order and history data so you can export what you need. Your firm still keeps the records the law requires.
Designated services for lawyers under Tranche 2
Acting for buyers or sellers in real property transactions. Includes conveyancing, settlement, and property transfers. All parties must be verified.
Establishing companies, trusts, partnerships, or other entities. Includes all directors, shareholders, trustees, and beneficial owners.
Holding client funds in trust accounts. Verification required before accepting funds. Ongoing monitoring while funds are held. You'll be notified if watchlist status changes before the money leaves trust.
Acting as nominee director, shareholder, trustee, or in similar fiduciary capacities. Providing registered office or business address services.
Large property deals, complex structures, or transactions involving high-risk jurisdictions. Enhanced due diligence may be required.
Litigation, dispute resolution, family law, wills and estates, employment law, and general legal advice typically do NOT require AML verification unless combined with designated services above.
AML/CTF breaches may not be covered by professional indemnity insurance. Penalties: significant civil penalties set in penalty units, or up to 2 years imprisonment for individuals. Protect your practice — verify now.
Everything lawyers need to know about Tranche 2
Start verifying your clients now. Be ready for July 1, 2026.