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From Global to Local. How to Use the National Risk Assessment in Your Law Firm


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At AML Sorted, we run a huge amount of risk assessments for our clients in the legal profession as part of the anti-money laundering and counter-terrorism finance requirements legislation.





When it comes to risk assessments however, what does this mean for you and your business?


What’s a National Risk Assessment and Why Should You Care?

The term “National Risk Assessment” (NRA) might sound like something for governments and regulators, not small or mid-sized law firms. But in reality, it’s one of the most useful tools for building an effective AML compliance program.


The National Risk Assessment sets out how criminals are laundering money in Australia, and how they’re likely to use your services to do it.


If your risk assessment doesn’t reflect those realities, it’s already out of date.


What Is the National Risk Assessment?

Published by AUSTRAC, the National Risk Assessment is a country-level report that:


  • Identifies the main sources of criminal funds

  • Highlights sectors most at risk (including legal, accounting and real estate)

  • Describes how money is moved, layered and integrated

  • Flags typologies, such as property flipping, shell companies and misuse of trusts


It draws from real cases, intelligence, law enforcement insights, and sector feedback. It’s a detailed, evidence-led guide to the actual risks facing Australia.


Key Risks for the Legal Sector

Here’s what AUSTRAC and the FATF have flagged when it comes to lawyers:


  • Real estate: Criminals use law firms to buy and sell property (residential and commercial), often at speed, or using inflated or suppressed values.

  • Trust accounts: These are especially attractive to criminals, as they allow movement of funds under the law firm’s name, creating an air of legitimacy.

  • Corporate structures: Lawyers help establish companies and trusts, which can be used to disguise ownership and make tracing funds more difficult.

  • False legitimacy: Simply involving a lawyer makes a transaction seem more credible, reducing the likelihood of third-party scrutiny.


These aren’t abstract risks, they’re showing up in real transactions. And that means your AML program needs to be built with them in mind.


Translating the NRA Into Firm-Level Action

So, how do you turn a national strategy into a firm-wide AML risk assessment?

Here’s a simple 3-step process:


1. Start with the NRA

Highlight the key risks that apply to the legal sector — especially the ones relevant to the types of work your firm undertakes.


2. Map them to your services

Ask:


  • Do we handle property work?

  • Do we open or administer trusts?

  • Do we manage a trust account?

  • Do we work with international clients or high-risk sectors?


This is your opportunity to reflect your actual exposure.


3. Build your controls accordingly

Design policies, checks, and escalation routes around the most likely typologies. Prioritise resources where the risk is highest.


Keep It Real (and Reviewed!)

Your AML program shouldn’t be a cut-and-paste job from someone else’s firm.


A good firm-wide risk assessment:


  • Reflects the size, structure, and services of your practice

  • Is reviewed at least annually, or whenever circumstances change

  • References external sources (like the NRA) as part of the rationale

  • Is documented and signed off by the leadership team


Regulators don’t expect every firm to face the same risks. But they do expect every firm to know and explain theirs.


To Summarise

The National Risk Assessment is there to help you. It’s not just a regulatory document — it’s a practical, strategic tool for designing smarter compliance systems. Start with the big picture. Then apply it to your firm’s reality.


Want support mapping national risks to your own compliance program?

We really do want to support lawyers and will never scare monger because of the legislative noise upon us all.


Our CEO, Amy Bell, is just a call away and you can book some free time directly with her.



Amy, and the whole AML Sorted team, helps law firms understand their risk exposure and build practical, proportionate systems that reflect the real world. Get in touch with us to find out more.

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