Map the service before mapping the supplier
List who obtains instructions, chooses or prepares the structure, supplies formation information, coordinates signatures and gives lodgement instructions. Assess the accounting practice's own acts against AUSTRAC's professional-services guidance. Distinguish a simple referral from work that directly advances formation. Both firms may have obligations for their respective services; a supplier invoice is not an allocation of statutory responsibility and a contract label is not a scope decision.
Identify which kind of arrangement you have
Separate outsourcing the formation task from outsourcing an AML function and from relying on CDD performed by another entity. These are different questions. AUSTRAC publishes distinct outsourcing and reliance guidance. Record which arrangement is being used for each part of the work and the basis for it. A forwarded identity document or vendor completion badge should not be treated as a compliant reliance arrangement without examining the applicable requirements.
Ask for evidence that supports the actual decision
For example, the provider may confirm a company was registered without confirming the proposed beneficial-owner information used by the practice. Agree which information and verification records can be supplied, when and through what secure channel. Identify what remains the practice's task. Check that the delivered records relate to the correct entity and people, rather than accepting a generic completion certificate. Record discrepancies and follow them to resolution.
Plan for exceptions and supplier failure
Keep a contact and escalation path for rejected documents, changed instructions, delayed records and suspected errors. Define who pauses the next implementation step and how the practice retrieves its records if the service ends. Review whether the actual delivery matches the arrangement and the practice's program. Avoid relying on an outsourced process that staff cannot explain, inspect or continue lawfully when the supplier is unavailable.
Official sources
Use these primary sources to confirm the current rules and apply them to your circumstances.
Sources checked .
Frequently asked questions
Does using a formation agent remove the practice's obligations?
Not automatically. Assess the acts your practice performs and the legal basis for any outsourced AML work or reliance.
Is supplier registration proof enough for CDD?
It proves only what the record establishes. Identify the customer and other required matters, then assess whether the available evidence supports them.
Can the provider's general terms replace a reliance assessment?
No. Check the applicable legal conditions and records access for the particular arrangement rather than assuming a generic contract satisfies them.
Put it into practice
Cassandra AML turns these obligations into a working system: designated-service decisions, customer due diligence, screening, monitoring and reporting records — hosted in Sydney, free to start.
This guide is general information for Australian professionals. It is not legal advice and does not replace the AML/CTF Act, the AML/CTF Rules or AUSTRAC guidance. Confirm your specific obligations with AUSTRAC or a qualified legal adviser. See our editorial and correction standards.