From 1 July 2026, new Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws will apply to the legal services we provide.
EFFECTIVE FROM
1 July 2026
APPLIES TO
All new & existing clients
VERIFICATION VIA
RealAML platform
What has changed and why
The Australian Government has expanded its Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws to cover a broader range of professional services providers — including law firms. From 1 July 2026, these obligations apply to lawyers who provide certain ‘designated services’ as defined under the AML/CTF Act.
For a Wills and Estates practice like ours, the designated services most likely to be relevant are those that directly advance a transaction — such as creating, amending or restructuring trusts, companies or SMSFs, or facilitating the transfer of real estate. It is important to note that many of the services we most commonly provide — including drafting Wills, Enduring Powers of Attorney and Appointments of Medical Treatment Decision Maker, as well as general estate planning advice and obtaining a Grant of Probate/Letters of Administration are not designated services under the Act and are therefore not directly subject to these new obligations.
However, because we also assist clients with matters that do involve designated services (such as trust structuring or restructuring and property transactions), we are required to have an AML/CTF compliance program in place across our practice. Part of that program involves verifying the identity of clients at the outset of certain matters.
These reforms bring Australia in line with international standards set by the Financial Action Task Force (FATF) and are designed to reduce the risk of the legal and financial system being used — whether knowingly or unknowingly — to facilitate money laundering, tax evasion, or the financing of terrorism.
In plain terms:
If your matter falls under a designated service, before we can begin work on your matter, we will be required by law to verify who you are. This is similar to the verification process you may already be familiar with from banking or other regulated industries.
What this means for you
Before we can commence work on your matter, we are required to complete a Know Your Client (KYC) process. This involves verifying your identity and collecting some basic background information. We use a secure, purpose-built platform called RealAML to make this process as quick and simple as possible.
Here is what to expect:
1. We send you a secure verification link
Once you have engaged us and signed our Cost Agreement, we will send you a secure link via the RealAML platform. This can be completed from your phone or computer and takes only a few minutes.
2. You provide your identification documents
You will be asked to upload a government-issued photo ID (such as a passport or driver’s licence) and complete a short face-matching step. This is encrypted and handled securely.
3. Answer a few short questions
You may be asked to answer some standard questions about the source of your assets or funds relevant to the matter. These are straightforward questions required under the legislation.
4. We confirm and proceed with your matter
Once verification is complete, we will confirm receipt and proceed as normal. We are unable to commence work until this step is finalised.
What information will we need
PHOTO ID
An Australian passport, current driver’s licence, or other government-issued photo identification.
PROOF OF ADDRESS
In some cases, a utility bill, bank statement, or similar document confirming your current residential address.
BENEFICIAL OWNERSHIP
For matters involving trusts, companies, or multiple parties, we may also need to verify any beneficial owners or controlling persons.
SOURCE OF WEALTH
We may require a brief description of the origin of assets relevant to the matter — for example, employment, inheritance, or sale of property.
How we protect your information
We take the privacy and security of your personal information very seriously. RealAML is an Australian-based, purpose-built compliance platform used by law firms across the country. Your identification documents and personal data are encrypted, stored securely, and used solely for the purposes of meeting our legal obligations under the AML/CTF Act.
Your information will not be sold or shared with third parties beyond what is required by law. We maintain and update our Privacy Policy in accordance with the Privacy Act 1988 (Cth).
About RealAML
RealAML is a specialist identity verification and AML/CTF compliance platform built specifically for Australian legal practices. It allows us to conduct client verification securely and efficiently, in a way that minimises the burden on you.
The platform is fully compliant with the requirements of the AML/CTF Act and enables us to maintain an accurate, auditable record of our obligations — protecting both our clients and our firm.
Does this apply to existing clients?
It depends on whether you qualify as a ‘pre-commencement customer’ under the AML/CTF Act.
Pre-commencement customer exception
Under the legislation, if you were already in an ongoing business relationship with us as at 1 July 2026 in connection with a designated service, you may qualify as a ‘pre-commencement customer’. If so, we are permitted to continue providing you with the designated service without needing to complete initial Customer Due Diligence (CDD) straight away.
This means that if you are an existing client with an active matter with us as at 1 July 2026, you will not automatically be required to go through the full identity verification process immediately.
When verification will still be required
Even as a pre-commencement customer, we will still be required to complete initial CDD — which includes identity verification — if either of the following applies:
- a suspicious matter reporting (SMR) obligation arises in relation to your matter; or
- there is a significant change in the nature or purpose of our business relationship — for example, if you instruct us in relation to a new or materially different type of matter — and that change results in your assessed money laundering or terrorism financing risk being medium or high.
For most existing clients returning for routine updates or additional documents of the same kind, this exception is likely to apply and the process will remain straightforward.
Not sure whether this applies to you?
Please contact our office and we will be happy to talk you through what is required for your specific matter. Our obligations under the AML/CTF Act are assessed on a case-by-case basis, and we will always let you know in advance if verification is needed before we can proceed.
Frequently asked questions
Is this specific to iWills Legal, or does it apply to all law firms?
This is a nationwide legislative change. All law firms providing designated legal services are required to comply from 1 July 2026.
What if I cannot complete the verification online?
Will this delay the start of my matter?
In most cases, no. The process typically takes only a few minutes. To avoid delays, we encourage you to complete the verification promptly once you receive your link from us.
What happens if I decline to provide my information?
Unfortunately, we will be unable to act for you in relation to designated services if we cannot verify your identity. This is a legal obligation and not a matter of discretion on our part.
Will I be charged for the verification?
There will be a small disbursement associated with the Virtual Verification of Identity (VOI) service. Please refer to your Cost Agreement for the applicable fee or contact our office.
Can iWills Legal stop acting for me?
In limited circumstances, yes. Under the AML/CTF Act and our professional obligations, we reserve the right to cease acting for a client immediately and without prior notice, where we are required or permitted to do so by our obligations under the AML/CTF Act, the Legal Profession Uniform Law, the professional conduct rules applicable to legal practitioners in Victoria, or any other applicable law or regulatory obligation.
In such circumstances, we may not be able to provide reasons for the termination — including where doing so would, or might constitute a contravention of the ‘tipping-off’ provisions under the AML/CTF Act, or would otherwise be contrary to law. If this occurs, you will be required to pay our fees for work done to date. This is an obligation imposed on all regulated entities under the AML/CTF framework and is not unique to our firm.
I am a referring professional — what do I need to know?
Please let clients know that identity verification may be required for their matter if it falls under a designated service before we can commence work on any new matter from 1 July 2026. We are happy to answer questions from your practice or your clients about what to expect.
Questions about these changes?
Our team is here to help. If you have any questions about how these requirements may affect you or your matter, please don’t hesitate to get in touch.