What does AMLCO even mean for Law Firm Regulations?

AMLCO means Anti-Money Laundering Compliance Officer. 

If you are a law firm in Australia, you will probably need to decide who in the firm is going to take on that role ahead of 1 July 2026. Yes, Tranche 2 (AUSTRAC's money laundering reforms) are coming into play soon.  

Scared to be the AMLCO? How AML Sorted can help 

We have been receiving lots of enquiries recently about whether the role of the Anti-Money Laundering Compliance Officer (AMLCO) can be outsourced to us.

It can be scary for someone to take on a new role like this because it’s such an important one with big consequences if it goes wrong. 

Law Firm AMLCO Responsibilities

Some of the responsibilities of the role of the AML compliance officer include the following list below:

• Receiving and assessing internal suspicious matter reports 

• Deciding if there are reasonable grounds to suspect money laundering or terrorist financing 

• Making the call on whether to send a report to AUSTRAC 

• Keeping careful records of decisions, SMR’s and contact with AUSTRAC 

• Protecting colleagues who raise concerns and ensuring confidentiality  

• Designing, maintaining and overseeing AML policies, controls and procedures 

• Making sure the firm risk assessment is completed and reviewed regularly 

• Overseeing staff training and making sure people know what to do in practice 

• Monitoring how well AML systems work and commissioning independent audits 

• Reporting back to the board or partners on how the firm is performing against its obligations 

Seems an awful lot of responsibility and work doesn’t it? No wonder firms are finding it difficult to find employee volunteers. This is why we are seeing many solicitors and conveyancers looking to outsource the role! 

Also, who in the firm has the time to do this?! 

On the flip side, it is a role that allows you to have a big part in protecting your firm, clients and the community they live in against criminals. 

Can You Outsource the AMLCO Role?

Technically, yes.

The Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 ((Section 26J(2)(a)) says:

“To provide flexibility for different business models, the requirement to ‘designate’ an AML/CTF compliance officer does not require that the AML/CTF compliance officer (AMLCO) be an employee of the reporting entity and may be engaged externally by the reporting entity.”

So, you can appoint someone external. But (and it’s a big but) we don’t actually recommend it.

Here’s why:

The law also says your AMLCO needs to have enough authority, independence, and access to resources and information to do their job properly. They must operate at management level. In reality, it’s really hard to achieve that with someone who isn’t in your firm day-to-day.

Plus, one of the AMLCO’s main functions is to oversee how your firm is complying with AML/CTF obligations and to coordinate that across the business. Again, not easy from the outside.

And here’s the clincher, even if you outsource the role, you still carry the legal risk. AUSTRAC has made that very clear.

So yes, it can be outsourced, but in our experience, it’s rarely the best option.

What You Can Do Instead?

Here’s where AML Sorted can help.

While we don’t recommend outsourcing the AMLCO role entirely, we absolutely can support your firm and whoever steps into it. We know this stuff inside out (thanks to many years helping law firms in the UK through very similar AML reforms), and we make the process much less daunting.

If you become your firm’s AMLCO, our AskAMLS Helpline gives you direct access to experts for practical guidance on things like:

• Talking through suspicious matters and red flags

• Understanding reporting obligations and when to seek consent

• Reviewing due diligence, source of funds, and source of wealth evidence

• Working out what you can and can’t say to avoid “tipping off”

  
  

And if you prefer to learn in person, we’re running a one-day AMLCO Masterclass in Melbourne, Sydney, Brisbane, Adelaide, as well as an online live day of training if you can’t make our in-person ones.

These Masterclasses are a great way to get everything you need to feel confident in the role.

Getting AML Sorted Before 1 July 2026

If your firm still needs to get ready for the reforms, our AML Sorted Program walks you through every step.

We do the heavy lifting, and you end up with everything you need to comply, including:

• A tailored firm-wide risk assessment

• Bespoke AML/CTF policies and procedures

• Client onboarding and due diligence workflows

• Role-based staff training

• Registers for high-risk clients, SMRs, staff screening, and training

• Annual audits and a compliance dashboard

• Regular policy updates and support

• New training modules every year

  
  

You’ll also have an AML Sorted Associate working alongside you, checking in regularly and helping you build your program over time. The team and I can’t emphasise enough that we are not robots, we are specialist AML compliance human folk supporting you through Tranche 2 and beyond. A small and mighty team I’d say!

ABOUT US

Final Thoughts

Yes, being an AMLCO is a big job, but it doesn’t have to be a scary one.

With the right support, training, and systems in operation, you’ll be well prepared for 1 July 2026 and ready to protect your firm and clients from financial crime.

So if you’re thinking, “This all sounds like a lot to grapple with,” remember you don’t have to do it alone.

“It is entirely appropriate and sometimes necessary for reporting entities to engage consultants to assist them in fulfilling aspects of their AML/CTF obligations". 

AUSTRAC 

To hear the full YouTube webinar from Austrac, you can tune in HERE.

👉 Find out more about our AMLCO Masterclasses

👉 Explore the AML Sorted Program

My colleague, Simon, will be your first port of call to get some time into our diaries or if you'd like to just find out a little more about how we can support you and your firm. You can email him: simon@amlsorted.com

Thanks for reading, 

Rhiannon

About Rhiannon Davies 

I’m an AML and legal compliance specialist who thrives on helping law firms make sense of complex regulations and turn them into practical, everyday processes that actually work.

After more than 15 years at Nationwide Building Society, where I developed a deep understanding of risk and operations, I moved into the legal compliance world in 2018. 

Since then, I’ve supported law firms of all sizes to build strong compliance cultures, implement policies and controls that stand up to scrutiny, and feel confident in meeting their regulatory obligations.