By profession
What accountants need for AML/CTF compliance
Accountants are captured by AML/CTF Tranche 2 for far more than handling client money. Here's the full list of designated services that bring an accounting practice into scope from 1 July 2026, and exactly what AUSTRAC requires — in plain English.
Accountants are one of the most under-prepared Tranche 2 sectors, partly because many assume capture is limited to "handling client money." It isn't. AUSTRAC's designated-services list for accountants is broad — and that's exactly why this profession is a money-laundering target. Here's what's actually in scope from 1 July 2026.
The designated services that capture accountants
Per AUSTRAC, an accounting practice can be captured when it provides any of these as part of a transaction:
- Assisting to plan or execute a transaction to buy, sell or transfer real estate
- Assisting to plan or execute a transaction to buy, sell or transfer a body corporate or legal arrangement
- Receiving, holding, controlling or managing a client's money, accounts, securities, virtual assets or other property as part of a transaction
- Organising equity or debt financing for a body corporate or legal arrangement
- Selling or transferring shelf companies
- Creating or restructuring bodies corporate or legal arrangements (e.g. forming companies or express trusts)
- Acting as — or arranging for someone to act as — a nominee director, secretary, power of attorney, partner or trustee
- Providing a registered office or principal-place-of-business address
(Source: AUSTRAC — professional designated services.)
AUSTRAC's stated reason accountants are captured: they handle large volumes of cash, facilitate international transactions and create complex legal structures — which is also why this list is wider than most people expect.
The important limit
General tax or accounting advice that only influences a possible transaction is not automatically a designated service — the service must directly advance the relevant transaction. So routine compliance work, tax returns and strategic advice that doesn't execute a transaction generally sit outside the net. Several adjacent activities are excluded entirely — see What is NOT a designated service. Because capture is service-based, work through Is my business an AUSTRAC reporting entity? against your actual engagements.
Your AML/CTF program
If you're captured, you need a documented AML/CTF program with three parts: an ML/TF risk assessment, AML/CTF policies (including CDD), and a governance framework with a fit-and-proper compliance officer. It must be proportionate to the size and complexity of your practice and approved in writing before you provide a designated service. (Source: AUSTRAC — about the reforms.) Start with How to do an ML/TF risk assessment.
CDD, reporting and records
- Customer due diligence: initial CDD (identify/verify customers and beneficial owners — generally individuals owning ≥25% or controlling the entity) and ongoing CDD, with enhanced CDD for higher-risk situations. (Sources: AUSTRAC CDD reform; AUSTRAC beneficial owner.)
- Suspicious matter reports: within 3 business days of forming the suspicion (24 hours for terrorism financing). (Source: AUSTRAC SMRs.)
- Threshold transaction reports: cash of A$10,000 or more, within 10 business days. (Source: AUSTRAC TTRs.)
- Records: generally 7 years. (Source: AUSTRAC record-keeping.)
Enrolment and cost
Accountants enrol (they don't register) via AUSTRAC Online by 29 July 2026. AUSTRAC does not charge an enrolment fee. Note the separate annual industry contribution levy — AUSTRAC says it usually applies only to businesses with earnings of A$100 million or more, a large number of transaction reports, or a high total transaction value, and Tranche 2 entities are not subject to the 2025-26 industry contribution — so most small practices won't receive a levy invoice. (Sources: AUSTRAC enrol with us; AUSTRAC industry contribution levy.)
The full deadline list is in Tranche 2 key dates: 1 July and 1 October 2026.
General information only, not legal advice. Reflects AUSTRAC guidance and the AML/CTF Act 2006 current to June 2026. Confirm your obligations with AUSTRAC (austrac.gov.au) or a qualified adviser.
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