AML/CTF Compliance

Anti-Money Laundering & Counter-Terrorism Financing Compliance

From 1 July 2026, RMB Lawyers is required to comply with Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws when providing certain designated legal services. This page explains what those obligations mean for you as a client, what information we may need to collect, and how we protect your privacy.

About Our AML/CTF Obligations

RMB Lawyers is enrolled with the Australian Transaction Reports and Analysis Centre (AUSTRAC) as a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act).

Australia's AML/CTF regime is designed to make it harder for criminal activity to be concealed through legitimate professional transactions. The regime requires certain businesses — now including law firms providing specified legal services — to put in place controls to identify, assess and manage money laundering and terrorism financing risk. Our compliance obligations are governed by the AML/CTF Act and the rules made under it, with AUSTRAC as the regulatory authority.

Which Matters Are Affected?

Not every legal matter triggers AML/CTF obligations. These requirements apply where RMB Lawyers is providing a "designated service" as defined under the AML/CTF Act. In practice, clients are most likely to be asked for additional information in matters involving:

• Property and conveyancing transactions, including purchases, sales and settlements.
• Corporate and commercial transactions, including business acquisitions, disposals and restructures.
• Matters involving trusts, SMSFs, companies or other entities with layered ownership structures.
• Client funds held in trust or involved in significant financial transactions.
• Entity creation, restructuring, shelf company sales or nominee arrangements.
• Matters where we are asked to manage, hold or transfer funds or assets on a client's behalf.

If your matter does not fall into one of these categories, it is likely that standard engagement terms will apply without additional AML/CTF steps.

What We May Need From You

Where AML/CTF checks are required, we will ask you to provide some or all of the following:

Identity Verification

• Government-issued photo identification (passport, driver's licence or equivalent).
• For individuals acting as a representative or attorney — evidence of authority and their own identification.
• For foreign nationals — equivalent identification from their country of origin, together with any required Australian recognition.

Beneficial Ownership and Control

• For companies: details of all persons who directly or indirectly hold 25% or more of the shares or voting rights, or who otherwise exercise significant control.
• For trusts and SMSFs: details of trustees, beneficiaries and, where relevant, the settlor.
• For other entities: information about the ultimate controllers and persons with decision-making authority.

Source of Funds and Source of Wealth

• Where the matter involves a significant transaction or a higher-risk profile, we may ask you to explain the origin of the funds involved and, in some circumstances, your broader source of wealth.
• This information is assessed as part of our risk-based compliance process and is not a reflection of any finding or assumption about your conduct.

Purpose and Nature of the Matter

• A brief explanation of the purpose of the transaction or engagement, where this is not apparent from the file.
• For ongoing matters, updated information may be required if circumstances change materially.

RMB Lawyers will only request information that is reasonably necessary to fulfil our legal obligations. We will tell you clearly what we need, why we need it, and how it will be used.

Our Process

In matters where AML/CTF checks are required, we follow a structured process to keep the steps clear and efficient:

1. At the commencement of your matter, your RMB Lawyers Lawyer and/or Licensed Conveyancer will notify you if AML/CTF checks are required.
2. We will send you a secure request for identification and any other required information. This will be processed through our verified compliance platform InfoTrack Compliance Centre.
3. We will review the information you provide and carry out the required verification and risk assessment steps.
4. If any information is unclear or incomplete, we will contact you promptly to clarify.
5. Once all required checks are satisfactorily completed, we will confirm that your matter can proceed.

We aim to make this process as straightforward as possible. To help avoid delays — particularly in time-sensitive or transaction-based matters — we encourage you to respond to any AML/CTF requests promptly and to allow a little extra time at the commencement of new engagements.

Privacy and Confidentiality

RMB Lawyers handles all personal information collected for AML/CTF purposes in accordance with:

• The Privacy Act 1988 (Cth) and the Australian Privacy Principles.
• Our professional confidentiality obligations under the Legal Profession Uniform Law (NSW).
• The record-keeping requirements of the AML/CTF Act.

Information collected as part of our AML/CTF process is used solely for the purposes of identity verification, compliance and client onboarding. It is stored securely using encrypted systems, with access limited to authorised personnel. We do not use AML/CTF information for marketing purposes and we do not sell, trade or share client data with third parties except as required or authorised by law.

Our identity verification process involves the use of a third-party compliance platform InfoTrack Compliance Centre that is subject to contractual obligations consistent with our privacy and confidentiality responsibilities.

Mandatory Reporting Obligations

As an AUSTRAC reporting entity, RMB Lawyers is required by law to:

• Report suspicious matters to AUSTRAC where there are reasonable grounds to suspect money laundering, terrorism financing or other relevant criminal activity.
• Submit threshold transaction reports for certain cash transactions at or above $10,000 AUD.
• Maintain records relating to designated services and AML/CTF compliance for the periods required by law.

Contact Us

If you have questions about our AML/CTF obligations, the information we have requested, or how your personal information is handled, please contact:

You may also raise any concerns with your Lawyer and/or Licensed Conveyancer or with any member of the RMB Lawyers team.