Establishment is the first service test
Where an accountant takes active steps that directly advance creation of an SMSF trust - drafting or finalising the deed, preparing trustee appointments, or lodging the fund's establishment documents - the work can be a professional designated service. Referral-only activity and routine work for an existing SMSF are not automatically designated.
Record the establishment file's scope decision: what the practice did, what the client did, and which steps directly advanced the creation. The presence of a tax return or audit engagement later does not change the establishment analysis.
Trustee and role services
If the practice or a related entity acts as a trustee of the SMSF, or arranges for another person to act, the item 7 analysis applies. The service is tested by the role, the nominator's control and the steps that directly advance the arrangement, not by the label 'trustee service'.
Individual trustees and directors of corporate trustees are relevant to CDD. Identify each trustee, the beneficial owners or controllers of a corporate trustee, and the persons on whose behalf the service is received.
CDD and ownership for SMSF work
The SMSF structure combines a trust, members and often a corporate trustee. The CDD file should show each layer rather than treating the fund as a single name.
- Complete initial CDD before providing a designated service
- Identify each member, trustee and controller
- Map the ownership of any corporate trustee
- Screen for PEPs, sanctions and adverse media
- Assess contributions and rollovers against the member's profile
Monitoring and reporting
SMSFs can be used to move wealth between related parties, which is why the accountant's monitoring role matters. A contribution from an unexplained source, a related-party loan without commercial terms or a rapid restructure of the fund's assets are the patterns to assess.
- Monitor contributions, rollovers and related-party transactions
- Review unusual or non-arm's-length activity
- Lodge SMRs within the deadline where suspicion forms
- Protect SMR-related information from tipping off
Official sources
Use these primary AUSTRAC pages to confirm the current rules and apply them to your circumstances.
Frequently asked questions
Is establishing an SMSF always a designated service?
No. The practice is captured where its own active steps directly advance creation of the trust. Referral-only or routine existing-fund work requires separate analysis.
Who are the customers for SMSF establishment?
Identify the instructing person, the members, the trustees and the beneficial owners or controllers of any corporate trustee under the customer-type rules.
Does SMSF audit work create AML duties?
Audit work itself is not a designated service on the same basis as establishment or role services, but the practice must separately test every service it provides. The audit file may also reveal reportable activity.
What records should an SMSF AML file keep?
The scope decision, member and trustee identity evidence, ownership mapping, screening, risk rating, contribution and transaction records, and any reporting decisions.
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.