Client Information: anti-money laundering and counter-terrorism financing (AML/CTF) compliance

Clayton Utz is committed to maintaining the highest standards of integrity and compliance with laws and regulations. From 1 July 2026, certain transactional advice and services we provide will be regulated by Australia's anti-money laundering and counter-terrorism financing (AML/CTF) laws. Under the law these services are referred to as 'designated services'.

The Australian Government has implemented these laws to strengthen Australia's financial and legal systems against money laundering, terrorism financing and proliferation financing.

What is the impact on clients?

Under the new laws we may be required to undertake client due diligence checks on you, even if you have an existing relationship with us. We may have to reach out to you to gather further information, which we will start doing for some clients from early 2026. We ask you to please work with us during this time to avoid any impacts to the advice and services we are providing.

We are working hard to ensure that the process is as simple as possible, with minimal disruption to the services we provide.

If you have any concerns or need further clarification about the checks we may conduct, please don’t hesitate to reach out to your Clayton Utz contact or email [email protected].

What does client due diligence entail?

Where we expect to provide transactional advice or services to a client that is covered under the AML/CTF laws we need to undertake checks to understand who the client is, before we provide that service.

This may include understanding the business activities of a client, how it generates money and the source of funds used in relation to a transaction, as well as understanding the individuals who ultimately own or control the client. We may need to verify the identity of certain individuals, including controlling individuals, beneficial owners and individuals acting on behalf of a client.

The information that we will collect about or from a client will depend on who we are acting for, and the nature and purpose of the services provided.

We will try and source as much information as possible from the public domain or data-based subscriptions services. However we may need to obtain some documentation from clients, for example trust deeds or structure charts in more complex business arrangements as well as individual identification documents.

We understand that this process may feel intrusive or time-consuming, but it is a necessary step to ensure compliance with the laws and to protect all parties involved.

What Happens If We Cannot Complete Checks?

We will work with clients to understand why there might be difficulties in providing certain information. However, if we are unable to complete the required AML/CTF checks, we may not be able to provide the relevant transactional advice or services to the client.

How will we keep client's information safe and secure?

The information security of our clients is of utmost priority. When we collect information from or about clients as part of the client due diligence process we will only use it for that purpose, and only keep the information for as long as the AML/CTF laws require us to.

Please see more about information security at Clayton Utz here.

What are our other obligations?

In addition to understanding our clients, we will be required to report certain cash transactions or suspicious activity to the financial crime regulator, AUSTRAC. We will not be able to tell you if we have done this.