Test the service, not the job title
A bookkeeper who only prepares and lodges BAS is generally outside the regime. The same bookkeeper can be captured when their own active steps directly advance a transaction involving client money or property, or when they provide entity services. Do not infer scope from the client's industry.
- Routine BAS preparation, lodgement and payroll processing are not designated services on their own
- Receiving, holding and controlling or managing client money as part of directly advancing a transaction may be item 3
- Entity formation, restructuring, nominee and registered-office services may be items 5-9
- Record the service analysis on each file where the boundary is arguable
Client money controls
Client money is the highest-touch area for bookkeepers. The control questions are who holds the money, what transaction it advances, who can move it and what evidence records each movement. Those answers drive CDD and monitoring.
- Identify whether the practice holds, controls or manages client money
- Separate client money from operating funds and reconcile it
- Confirm the transaction the money directly advances and the customer set
- Screen unusual payments and third-party instructions
Onboard and monitor
Bookkeeping records are unusually detailed, which makes them valuable evidence - for the practice and for an examiner. Keep the CDD decision linked to the service and the transactions rather than in a separate folder.
- Complete initial CDD before providing a designated service
- Identify the business customer and its beneficial owners
- Screen for PEPs, sanctions and adverse media
- Record the risk rating and review it on trigger events
- Report suspicious activity within the applicable deadline
Records and training
A BAS practice can demonstrate a strong control environment with the same records it already keeps, once they are structured: who was verified, when, from which source, and why the service was or was not in scope.
- Retain scope, CDD, transaction and reporting records for the required period
- Restrict access to suspicious-matter work
- Train staff on the services the practice actually provides
- Set the review calendar and test the workflow
Official sources
Use these primary AUSTRAC pages to confirm the current rules and apply them to your circumstances.
Frequently asked questions
Are all bookkeepers captured by Tranche 2?
No. The trigger is a designated service. Routine BAS preparation and lodgement are not designated on their own; client-money, entity and transaction services require separate analysis.
What is item 3 for a bookkeeper?
Item 3 covers receiving, holding and controlling or managing money or property as part of directly advancing a specified transaction. A bookkeeping practice that holds client money for a transaction must test it against the item and its boundaries.
Do we need to verify every client?
You must complete applicable customer identification before providing a designated service. For routine non-designated work, the AML/CTF CDD obligation does not arise, but other professional duties still apply.
Can we use the same client file for BAS and AML records?
Yes, where the file separates the AML/CTF evidence and restricts sensitive reporting. A connected file makes both the ATO and AUSTRAC reviews easier to respond to.
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.