AML/CFT for law firms and conveyancers — proportionate, documented, done
The annual report window is 1 July – 31 August. There are no extensions.
Law firms and conveyancing practices are DIA-supervised, and the exposure runs through exactly the work you do most: conveyancing, trust accounts, forming companies and trusts, and holding client funds. Ten minutes of plain-English questions gets your annual report answers formatted for AML Online — and a scorecard showing whether the documents behind them stand up.
Get my answers free →Led by a chartered accountant — CA ANZ member, qualified twenty years.
Where small firms come unstuck
An inherited programme nobody has reviewed
A risk assessment and programme written years ago — often by someone who has since left — no longer describes the firm you actually run. Since 19 May 2026 the risk assessment must also incorporate the National Risk Assessment 2024; documents older than that almost certainly don't.
Trust account and client funds banding
The annual report asks for banded values across client funds held, transactions captured and international transfers. Assembling those numbers at 9pm on 30 August is how errors happen — the tool collects them once, in the portal's own bands, reusable every year.
The three-year audit clock
Your risk assessment and programme must be independently audited every 3 years from the last audit report's date. Firms routinely discover the clock expired mid-window. The scorecard does the date arithmetic for you.