Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF)
Australia’s AML/CTF regime is regulated and monitored by AUSTRAC, the national financial intelligence agency. It imposes strict compliance and reporting requirements on financial institutions, legal professions, accountants and other designated businesses to disrupt money laundering, terrorism financing, and other serious financial crimes
Keystone Lawyers is committed to upholding the highest standards of professional integrity and regulatory compliance. From 1 July 2026, certain advisory and transactional services we provide will be subject to Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime. These services are defined under the legislation as “designated services.”
What does this mean for our clients?
As part of these obligations, Keystone may need to carry out client due diligence checks. This may apply even where we already have an established relationship with you.
We are incorporating these requirements into our existing onboarding and engagement processes and are using technology to ensure the process is as efficient and consistent as possible. We appreciate your cooperation in providing any requested information promptly so that there is minimal disruption to the delivery of our services.
Our aim is to make this process straightforward and to minimise any inconvenience to you.
If you have any questions or would like further information about these requirements, please contact your Keystone representative.
What is involved in client due diligence?
Where we provide services that fall within the scope of the AML/CTF legislation, we are required to take reasonable steps to verify our client’s identity before commencing the relevant work.
Depending on the circumstances, this may include:
- Gaining an understanding of your business activities and how funds are generated
- Identifying the source of funds involved in a transaction
- Determining who ultimately owns or controls an entity
- Verifying the identity of relevant individuals, such as directors, beneficial owners or authorised representatives. This is usually done by way of a passport and driver’s licence.
The type of information we collect will vary depending on the nature of the client and the services being provided.
Where possible, we will obtain information from publicly available sources and trusted data providers. However, we may also need to request:
- Documents such as trust deeds, constitutions or organisational structure charts (particularly for more complex entities); and
- Personal identifying details (for example, full name, date of birth and residential address), and in some cases copies of identification documents.
We understand that these requirements may feel detailed or time-consuming. However, they are a necessary part of meeting our legal obligations and are applied consistently across all relevant engagements.
What if the required checks cannot be completed?
We will work with you to address any challenges in providing the requested information. However, if we are unable to complete the necessary AML/CTF checks, we may be unable to proceed with certain services.
How we protect your information
Safeguarding client information is a priority for Keystone. Any personal or business information collected as part of our AML/CTF obligations will be used solely for compliance purposes and managed in accordance with applicable privacy and data security requirements.
We will retain this information only for as long as required under the relevant legislation.
Additional regulatory obligations
In addition to conducting client due diligence, we may be required to report certain transactions or suspicious matters to Australia’s financial intelligence agency, AUSTRAC. In some circumstances, we are prohibited by law from notifying clients if such a report has been made.