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How Law Firms Are Meeting Tranche 2 Requirements Without Adding Headcount

Legal practices face real constraints on time and resources. Here is a practical approach to running a compliant AML/CTF program without building an internal compliance function from scratch.

12 March 20266 min readClientCheck Editorial
How Law Firms Are Meeting Tranche 2 Requirements Without Adding Headcount

The AML/CTF Act does not require legal practices to hire dedicated compliance staff. It requires firms to have an AML/CTF program, deliver training, and maintain records. For most small and mid-sized law firms, identifying who is responsible, what they need to do, and when it needs to happen is where the effort goes.

The most effective approach is usually to centralise responsibility in one person — the AMLCO — and give them a manageable process they can run consistently. The AMLCO does not need to be a compliance specialist. They need to understand the obligations, know how to assess risk, and have a reliable system for keeping records.

Onboarding is the highest-friction point for most firms. Matter intake already involves collecting client information, but AML/CTF adds verification steps, risk scoring, and structured documentation that most practice management systems were not designed to handle. Adding these steps to existing workflows without dedicated tooling often means they happen inconsistently or get skipped under time pressure.

ClientCheck gives legal practices a purpose-built flow for AML/CTF client onboarding. It is not a full practice management system — it handles the specific compliance layer that practice management systems do not. Fee earners complete structured checks, evidence is logged against the client file, and the AMLCO has a clear view of program status. That is often enough to run a defensible, low-overhead program.

Need a practical way to handle AML/CTF client checks, risk scoring, and evidence capture? ClientCheck helps Australian firms run compliant onboarding workflows aligned with AUSTRAC expectations. Start with a walkthrough and see how your team can go live fast.

Key Takeaways

  • The AML/CTF Act requires a documented program, staff training, and maintained records — not a dedicated compliance function.
  • Centralising AMLCO responsibility in one person with a manageable process is usually the most practical approach for small legal firms.
  • Practice management systems were not designed to handle AML/CTF — the compliance layer needs a separate, purpose-built approach.
  • The right tooling lets fee earners stay focused on legal work while the compliance record builds automatically in the background.

Build a Defensible AML/CTF Program Before July 2026

See how ClientCheck helps your team run compliant workflows with less friction, better evidence quality, and stronger oversight.