For accountants
AML/CTF for accountants: Australia's service-based regime
Australia's expanded AML/CTF regime applies from 1 July 2026 to an accounting business when it provides a professional designated service with the required geographical link. It does not regulate every accountant or convert all accounting, audit and tax work into designated services. The statutory list focuses on specified transaction assistance, company and trust services, management of client property, certain acting arrangements and registered-address services. The correct starting point is therefore a service inventory based on active steps and authority. Once a captured service is identified, the reporting entity must connect enrolment, its AML/CTF program, customer due diligence, monitoring, reporting and records to the real workflow.
See the accountants AML/CTF workspaceInventory services at task level
Break broad engagements into activities. General accounting advice, tax compliance, audit work or a valuation does not become designated only because it affects a decision. Ask whether the firm takes active steps that directly advance a listed transaction or structure. Relevant services include assistance with specified real-estate, body-corporate or legal-arrangement transfers; receiving or managing property for a transaction; qualifying entity-related equity or debt finance; shelf companies; creation or restructuring that changes legal form; specified acting roles; and official address services.
Record the table 6 item, customer instruction, contemplated outcome, work performed and direct-advancement reasoning. Review the scope as a matter develops. Advice about whether to sell a company may sit outside scope, while later negotiation, transaction due diligence, sale documents or settlement preparation for an identified sale may be captured. A robust intake process creates a new review when the instruction moves from analysis to implementation.
Identify the reporting entity and prepare its program
Determine which legal entity carries on the business and contracts to provide the service. A multidisciplinary group should not assume that service teams are separate reporting entities merely because they have different brands or cost centres. Map referrals, outsourcing and shared delivery so each entity understands the designated service it provides. Address AUSTRAC enrolment and any other applicable registration or notification obligations on the current timetable.
The AML/CTF program must be adopted before the entity provides a designated service. Base its risk assessment on actual customers, services, delivery channels and countries. The program should govern initial and ongoing CDD, enhanced CDD, transaction monitoring, suspicious-matter escalation, regulatory reports, record keeping, personnel checks, training, compliance oversight and independent evaluation. Tailor AUSTRAC starter materials to the firm's facts and confirm that any eligibility assumptions remain true.
Embed CDD before regulated work begins
First establish the person receiving the designated service. Identify representatives and verify their authority. For entities and trusts, collect and verify the information required for the customer type, understand ownership and control, identify relevant beneficial owners and establish the purpose and intended nature of the relationship. Apply PEP and targeted-financial-sanctions checks and assess customer, service, delivery-channel and geographic risk under the program.
Initial CDD is ordinarily completed before the designated service is provided, so engagement and job systems need a meaningful hold. Define the evidence required to release the service, who approves higher-risk customers and what happens when information is missing, inconsistent or unreliable. The process must also accommodate the wider customer population identified for company and express-trust creation services rather than checking only the person who signed the engagement.
Monitor activity and escalate concerns confidentially
Monitor the designated-service relationship against the expected purpose, activity and risk profile. Keep CDD information current and review material changes in ownership, control, representatives, jurisdictions, authority, transaction scope or payment flows. Apply enhanced CDD where required. Risk indicators such as opaque controllers or unexplained third-party funds require inquiry and escalation; they are not automatic proof of money laundering or terrorism financing.
Give staff a confidential route to the AML/CTF compliance officer for information that may require a suspicious matter report. Ensure applicable threshold transaction, international funds transfer or other regulatory reports are identified and lodged when the statutory tests are met. Protect report information and avoid communications that could constitute prohibited tipping off. Document decisions without exposing confidential reporting material to operational users who do not need it.
Retain evidence and test whether controls work
Keep service-scope decisions, customer and representative information, authority evidence, ownership and control analysis, verification sources, screening, risk ratings, monitoring results, enhanced CDD, internal escalations, reports, approvals, program versions and training records for the applicable periods. The file should show the order of events and why the firm was permitted to begin or continue the service.
Test a representative sample from intake through completion. Confirm that outside-scope decisions have evidence, holds prevent premature work, ownership chains are resolved, alerts reach the right person and changes trigger review. Feed findings back into the risk assessment and program. Revisit the current Act, Rules and AUSTRAC guidance whenever the firm introduces a service, acquires a practice or changes its operating model.
Official sources
Use these primary AUSTRAC pages to confirm the current rules and apply them to your circumstances.
Frequently asked questions
Are all accounting firms regulated by AUSTRAC from 1 July 2026?
No. The professional title does not decide the issue. A business must assess whether it provides a designated service with the required geographical link. A firm with a captured service must meet the applicable obligations for that reporting entity and service.
Does one captured service make every accounting engagement designated?
No. It can make the legal entity a reporting entity, but each service and customer relationship still requires accurate scope. Routine accounting work is not automatically captured. Entity-wide conditions can matter for particular boundaries, so document both the firm and service analyses.
Can an accounting firm use AUSTRAC's starter kit unchanged?
The starter kit may assist firms that fit its stated assumptions, but it must be customised to actual services and risks. A firm with complex ownership work, offshore exposure, client-money authority or services beyond those assumptions may require more extensive controls.
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.