The first annual report by law firms which are reporting entities is due to be submitted to the Department of Internal Affairs no later than 31 August 2019.

AML/CFT — Annual reporting aims to give practical guidance on the annual reporting obligations pursuant to section 60 of the Act.

The Practice Briefing notes that many, but not all, law firms are captured under the AML/CFT legislation and recommends that all lawyers use the annual reporting deadline to review their business activities to determine if there have been any changes which might now require them to be supervised as a reporting entity and to comply with the AML/CFT Act, including annual reporting obligations.

It says the annual report can be submitted online using AML Online, which is a new secure platform for businesses to engage with the department online.

"It's important that you register with DIA and activate your AML Online account in time to submit your annual report."

The Practice Briefing says failure to file an annual report is a "civil liability act" and may attract fines of up to $200,000 for an individual or $2 million for a body corporate or partnership.