For BAS agents
Routine bookkeeping or designated service? A guide for BAS agents
Routine bookkeeping is not automatically a professional designated service. The AML/CTF analysis changes when the practice accepts authority or performs active steps that match a service in table 6. The dividing line can be missed when company administration, payment processing and transaction support are bundled into a monthly bookkeeping package. A reliable scope review separates data entry and fixed processing from discretionary control of property, entity or trust creation, registered-address services and active assistance with specified transactions. It then records why each component is inside or outside scope and when that conclusion must be revisited.
See the bas agents AML/CTF workspaceMap the ordinary bookkeeping baseline
Typical reconciliation, coding, ledger maintenance, preparation of management reports, BAS preparation and payroll calculation do not become designated merely because they concern money. The practice should still describe the exact activity and authority. A workflow that imports bank data and prepares an approval file is different from one that lets staff choose recipients, change payment purposes or move client funds without a fresh instruction.
Use the engagement, bank mandate and actual system permissions together. Staff may have technical access that is constrained by contract, dual approval and fixed instructions, or they may in practice exercise broader discretion than the written mandate suggests. Interview the people who perform the work and sample real files. The scope record must reflect operational reality rather than the name of the service package.
Examine payment processing under table 6 item 3
Item 3 concerns receiving, holding and controlling, including disbursing, or managing another person's money, accounts, securities, virtual assets or other property as part of directly advancing a transaction. Receiving, holding and controlling operate as a composite idea. Managing can apply without possession where the practice has substantive authority and discretion over how property is dealt with.
AUSTRAC's current professional-services guidance uses routine payroll, supplier, rent, GST and PAYG payments as examples in explaining the boundary. Processing fixed obligations without discretion to vary the payee, amount, timing, conditions or purpose is less likely to be managing. That is not an exemption based on job title. Record the source of each instruction, approval control, permitted variation and whether the work directly advances a transaction.
Check for a separate entity or transaction service
A monthly package may include steps that are independently captured. Preparing and lodging documents that directly advance creation of a company or express trust can be a creation service. Drafting or implementing a restructure can be item 6 when it changes the legal form of a body corporate or legal arrangement. Helping negotiate, prepare or execute a sale or transfer of a body corporate, legal arrangement or real estate, or qualifying entity-related equity or debt financing, can also move beyond general business advice.
Company secretarial work deserves a granular review. Updating internal registers or reminding a client about a filing is not automatically designated, but acting or arranging for another person to act as a nominee director, secretary, partner or trustee is a listed service. Allowing a business address to be used as the customer's registered office or principal place of business is another separate table 6 item, even if no additional fee is charged.
Apply boundaries at the correct legal-entity level
The Act contains boundaries for item 3, including payment for the provider's own goods or services, certain payments reasonably incidental to a non-designated service, specified court, government and other payments, and conduct covered by another designated service. Each boundary has conditions. It should be tied to the actual payment flow and provision rather than converted into a broad category called routine bookkeeping.
AUSTRAC explains that the reasonably-incidental condition is assessed at business level. If the same legal entity provides another designated service, it may not be available merely because the payment team is organisationally separate. Map all service lines of the entity that signs the engagement and invoices the customer, then document any boundary with the facts that satisfy each condition.
Create reassessment triggers for changing engagements
An outside-scope assessment can become wrong when authority expands. Trigger a fresh review if the practice gains discretion, receives third-party funds, is asked to redirect a payment, begins holding money, establishes a new entity, supplies a registered address, takes a nominee role or starts advancing a specific sale or financing. Pause the new component until the reporting-entity and CDD steps have been addressed.
Retain the original scope assessment, engagement and authority documents, workflow evidence and later reviews. Train staff to recognise changes rather than expecting them to interpret table 6 unaided. A concise escalation form can capture the customer, requested task, relevant property or transaction, authority requested and deadline so the compliance officer can make and record a timely decision.
Official sources
Use these primary AUSTRAC pages to confirm the current rules and apply them to your circumstances.
Frequently asked questions
Are payroll and supplier payments always outside AML/CTF scope?
No. Fixed processing without substantive discretion is less likely to be management, but the complete item 3 test and any statutory boundary must be applied. Broader authority to decide or redirect payments may change the result. Record the mandate and actual controls.
Does a virtual CFO service automatically become designated?
No. Virtual CFO is a commercial label, not a table 6 category. Break the service into actual activities. General analysis may be outside scope, while discretionary management of property, entity creation, specified transaction assistance, nominee work or address services may be captured.
Should an outside-scope bookkeeping decision be reviewed?
Yes. Review it when the engagement, authority, customer structure, payment flow or transaction work changes and at the interval required by the practice's governance. Keep the facts and reasoning so staff can recognise the exact trigger for reassessment.
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.