Australia issues sanctions guidance for legal professionals, accountants & real estate agents

23 March 2026

Australia has released 3 guidance notes to assist legal professionals, accountants and real estate agents in Australia understand their sanctions obligations ahead of reforms to Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) laws.

Legal services

The sanctions compliance for legal professionals note says:

• The Australian Sanctions Office (ASO) has issued a class‑based permit allowing legal professionals to provide advice, representation and ancillary services to designated persons.

• From 1 July 2026, AML/CTF obligations will apply to legal practices providing designated services, including assisting with transfers of legal entities or arrangements.

• Legal professionals must conduct due diligence, screen clients and associates against the Consolidated List, and avoid dealing with controlled assets.

• They should assess sanctions risk before accepting instructions and report suspected breaches to the ASO, AFP or AUSTRAC.

Accountants

The guidance for accountants explains how accounting services fall within the expanded AML/CTF regime from 1 July 2026.

• From 1 July 2026, accountants providing designated services must verify clients and beneficial owners, identify designated persons and maintain AML/CTF policies preventing dealings with sanctioned persons.

• Accountants must freeze controlled assets, report attempted breaches and apply enhanced checks where ownership chains or funding sources are unclear.

Real estate agents

The real estate guidance says:

• Real estate professionals face heightened risk due to high‑value property transactions and foreign involvement.

• From 1 July 2026, designated services such as brokering sales, transfers and long‑term leases will trigger AML/CTF obligations.

• Agents must identify clients and relevant parties, check them against the Consolidated List and avoid facilitating the use of controlled real estate or funds.

• They must investigate complex ownership structures, apply a risk‑based approach and report suspicious matters.

Across all three sectors, DFAT and AUSTRAC stress due diligence, ongoing monitoring, and early escalation where sanctions risks are identified. See our Australia guidance pages for more sanctions information.