June 2026 guidance updates: when holding client money is a designated service, the 28-day rule for counterparties, and insolvency practitioners

Professional services (12 June)

• Item 3, receiving, holding, controlling or managing a person's money or property, applies only where the service directly advances a transaction. Routine payment processing under pre-agreed obligations is not 'managing'; AUSTRAC's example is a bookkeeper running payroll, supplier, rent and tax payments from a client's account.
• Exclusions confirmed: payment for your own services; money held only for payments incidental to non-designated work where the practice provides no other designated service (a litigation practice holding settlement funds); payments to or from government bodies, courts, the ATO and insurers; and, by the Rules, rental income managed through a real estate agency's trust account.
• Your customer under item 3 is your direct client, not a counterparty whose money passes through your account.
• Item 7 may not apply where a legal practitioner acts as a filing agent or nominee for administrative steps.
• Legal aid commissions, community legal centres and barristers acting for Australian government bodies are exempt.

Real estate (12 June)

'Real estate' includes leasehold interests of more than 30 years, excluding options to renew or extend, and granting or re-granting such a lease counts as selling real estate.

Starter kits and delayed due diligence (19 June)

All starter kits were updated. The conveyancing and real estate kits adopted the revised timeframe for completing initial due diligence on the counterparty: 28 days after exchange of contracts or 3 days before settlement, whichever is earlier (previously 15 days), plus a requirement to record steps taken with uncooperative counterparties and to report suspicious activity.

Insolvency practitioners (19 June)

New guidance explains how the professional designated services apply to insolvency and restructuring work, who the client is, and how to decide whether a practitioner is a reporting entity.