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Building an AML Program That Actually Works: A Practical Guide for Law Firms


Man with beard and blue shirt sitting at laptop

A Policy Is Not a Program

Most law firms already have an anti-money laundering (AML) policy in place. But that’s only one part of a functioning compliance program.


The reality is: a document no one uses doesn’t protect you from risk.


An effective AML program is embedded into your firm’s culture, processes, and decision-making. It’s not just about ticking boxes — it’s about creating systems that actually help you prevent financial crime.


What Makes a Good AML Program?

A strong AML program is more than just client due diligence. It has multiple working parts that support each other.


Here’s what your program should include:


1. A Firm-Wide Risk Assessment

Your program must be built on a realistic understanding of where your firm is vulnerable — from services offered, to types of clients, to geographical risk.


 2. Clear Policies and Procedures

These should be practical, role-specific, and easy to follow. No 50-page PDFs no one reads. Think flowcharts, checklists, and FAQs.


3. Appointed Compliance Officer

This person needs to have real authority, access to information, and time to do the role properly — not just a title added to an existing job.


4. Training for Everyone

From reception to partners, everyone needs AML awareness training that’s tailored to their role. One-size-fits-all won’t cut it.


5. Client Matter Risk Assessments

Firms must assess risk at the client and matter level — not just once at onboarding, but whenever circumstances change.


6. Record-Keeping Systems

You need to evidence the decisions you’ve made, the checks you’ve done, and the rationale behind them. If it’s not documented, regulators may assume it didn’t happen.


What Happens When AML Programs Don’t Work?

The most common failures we see are from firms who think they are compliant, but whose systems don’t actually work in practice.


Common signs of an ineffective program:


  • The compliance officer doesn’t have time or authority to act

  • Risk assessments are copied from templates and never updated

  • Training is generic and quickly forgotten

  • Staff don’t know what to do when something feels “off”


These aren’t small problems — they expose your firm to regulatory breaches, reputational damage, and serious legal consequences.


Getting it Right from Day One

If you're building your AML program now, here are three things to focus on:


  1. Design it for your actual firm — not someone else’s.

  2. Involve your people — the best policies come from understanding the day-to-day reality of how legal work is delivered.

  3. Don’t wait for the perfect template — the best programs evolve over time. Start now and iterate.


Final Thoughts

An AML program isn’t something you file away. It’s a living, breathing part of how your firm operates.


Get it working — and it won’t just protect you from penalties. It will help you sleep better at night, knowing your systems are strong, your team is trained, and your clients are who they say they are.


Want help building an AML program that works in the real world?

AML Sorted helps Australian law firms set up effective, affordable compliance programs tailored to their services. Let’s talk.

 
 
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