AML/CTF for accounting practices: every obligation, with its source

The short version

The Act does not regulate accountants as a profession. It regulates services. If your practice provides one of the professional services in Table 6 of section 6, you are a reporting entity for that service and the rest of this page applies.¹ Ordinary tax returns, BAS, payroll and bookkeeping are not Table 6 items.

1. Decide which of your services are designated

   Engagement by engagement, against Table 6 and the exclusions for client money. s 6 s 6(5C)

2. Enrol with AUSTRAC

   Within 28 days of your first designated service. The date for firms already acting before 1 July 2026 was 29 July 2026. s 51B

3. Have your program in place before you act

   A written ML/TF risk assessment and AML/CTF policies, approved by a senior manager. s 26B s 26P

4. Check each client before you start

   Scaled to the client's risk, then keep monitoring. s 28 s 30

5. Report and keep records

   Suspicious matters, cash of A$10,000 or more, the annual compliance report, and 7-year records. s 41 s 43 s 47

Which of your services are designated

Table 6 lists nine professional services. The customer column matters, because it tells you whose identity you must establish.²

The limit on item 3. Item 3 does not apply where the money or property is payment to your practice for its own goods or services; where you provide no other designated service and the money is for payments reasonably incidental to a service that is not designated; where it is received or payable under a court or tribunal order; where it is a payment to or from a government body, a court, a public international organisation or a licensed insurer; where the service is another designated service; or in a circumstance set by the Rules.³ AUSTRAC's accountant starter kit puts it this way: "Accountants operating trust accounts in the absence of any other designated services aren't covered."⁴

AUSTRAC's worked examples. An accounting practice that receives a client's money into its own account and pays the client's lease and a family member's school fees on the client's instructions is likely to be providing item 3, unless a section 6(5C) exclusion applies. A bookkeeper who pays routine payroll, suppliers, rent and tax from the client's account on fixed instructions, with no discretion to redirect the money, is less likely to be managing it, and in any case would generally be covered by the "reasonably incidental" exclusion if it provides no other designated service.⁵ Tax advice about selling a company is not item 2 on its own. The service starts once you are instructed to act on a sale to a buyer or, where several potential buyers have been identified, once negotiations begin with one or more of them.⁵

Where you act. An item applies only to a service provided at or through a permanent establishment in Australia, or through a foreign permanent establishment of an Australian resident or a resident's subsidiary.⁶

Not sure? AUSTRAC's Professional designated services page walks through each item, and our free six-question check records your answers. AUSTRAC links on this page open in a new window. AUSTRAC has not reviewed or endorsed this guide.

Enrolment

1. 1 July 2026

   Program, customer due diligence, reporting and record-keeping obligations began for professional services under Table 6.

   Sch 3 item 11
2. 29 July 2026

   Enrolment was due for a practice that was already providing a Table 6 service before 1 July 2026, and no other designated service.

   A practice that starts later has 28 days from its first designated service. The obligation to enrol continues until you apply, and each day late is a separate contravention.

   Sch 3 item 12 s 51B
3. 28 August 2026

   AUSTRAC said it had begun issuing section 167 notices to businesses, including accountants, that appear to provide designated services but have not enrolled.

   s 167 AUSTRAC media release

The application asks about each designated service and its start date, your business and its beneficial owners, staff numbers and approximate turnover, and ends with a declaration that the information is true and correct.⁷ Tell AUSTRAC of any change within 14 days.⁸ Our enrolment guide goes through it step by step.

Your AML/CTF program

Your AML/CTF program is two documents: your ML/TF risk assessment and your AML/CTF policies.⁹

• Risk assessment. Assess the money laundering, terrorism financing and proliferation financing risks you may reasonably face, having regard to your services, clients, delivery channels and the countries you deal with. s 26C Review it after a significant change, and at least once every 3 years. s 26D No designated service without an up-to-date one. s 26E
• Policies. Procedures, systems and controls that manage those risks, covering client checks, personnel due diligence, training and an independent evaluation at least once every 3 years. Review them at least once every 3 years, and follow them. s 26F s 26G
• Before the first service. Document both before you first provide a designated service, and document each update within 14 days. s 26N Rules 5-15 A senior manager approves both, and every update. s 26P
• Oversight and a compliance officer. The governing body oversees the program. s 26H Designate a compliance officer at management level, resident in Australia and fit and proper, within 28 days of your first designated service, and notify AUSTRAC within 14 days. s 26J s 26K s 26M

Sole practitioners. If the reporting entity is an individual, the governing body is that individual.¹⁰ The compliance officer's regular reports to the governing body are not required where the reporting entity is an individual, or where the compliance officer is the same individual as the governing body.¹¹ Our program guide sets out what each document must contain.

Checking clients

Before you start a designated service, you must have established on reasonable grounds who the client is, who is behind them, whether any of those people is a politically exposed person or designated for targeted financial sanctions, and the nature and purpose of the work. You collect KYC information, and verify it "using reliable and independent data", to the extent appropriate to the client's risk.¹²

• Beneficial owners. An individual who ultimately owns 25% or more of the client, directly or indirectly, or who controls it.¹³
• Scale to the risk. Simplified measures only where the client's risk is low and no enhanced trigger applies. Enhanced measures are mandatory in the cases section 32 lists, including high risk and a foreign politically exposed person. s 31 s 32
• Politically exposed persons and sanctions. A senior manager approves before you act for a foreign politically exposed person, and for a domestic or international-organisation one where the risk is high, and you establish their source of wealth and funds. Rules 5-5 Rules 6-23 Your policies must also stop assets being made available to a person designated for targeted financial sanctions. Rules 5-3
• Ongoing checks. Monitor for unusual transactions and behaviour, and refresh KYC at a frequency suited to the risk. s 30
• Existing clients. A client whose relationship with you involved only Table 6 services at the start of 1 July 2026 is a pre-commencement customer: initial checks apply only once a suspicious matter reporting obligation arises, or a significant change in the nature and purpose of the relationship makes the client's risk medium or high. Keep monitoring these clients in the meantime. s 36 s 30
• Relying on others. You may rely on another regulated party's checks where the Rules conditions are met. s 37A s 38 Rules 6-29 Rules 6-31

Our customer due diligence guide covers each step in detail.

Reports to AUSTRAC

• Suspicious matter report (SMR). Within 3 business days of forming a suspicion; within 5 business days where you reasonably believe some, but not all, of the information may be privileged and the privilege belongs to someone else (with an LPP form); within 24 hours for terrorism financing. s 41 The report's content is set by Rules 9-1 to 9-4. Our SMR guide explains the triggers.
• Threshold transaction report (TTR). Within 10 business days of a transaction involving A$10,000 or more in physical currency, meaning notes and coins. s 43 s 5
• Annual compliance report. The first reporting period is 1 July 2026 to 30 June 2027. Lodge the report in AUSTRAC's approved online form between 1 July and 30 September 2027. s 47 Rules 9-9 It is a report, not a statutory declaration.

Tipping off, and the accountants' exception

Once a suspicious matter report has been made, or must be made, you must not disclose that fact, or the report's contents, where the disclosure would or could reasonably be expected to prejudice an investigation. The maximum penalty is 2 years' imprisonment or 120 penalty units (A$43,680), or both. It does not matter whether an investigation has started.¹⁴

Section 123(4) gives a narrow exception. It applies to a reporting entity (or its officer, employee or agent) that is a qualified accountant, or a partnership or company using qualified accountants to supply accountancy services, where the information relates to a client's affairs and the disclosure is made in good faith to dissuade the client from conduct that is, or could be, an offence.¹⁵ A qualified accountant is a member of CPA Australia, Chartered Accountants Australia and New Zealand, the Institute of Public Accountants, or a body the Rules specify.¹⁶ A person relying on the exception bears an evidential burden, so record what you said and why. Your policies must include safeguards against tipping off. Rules 5-13

Records

Records must be in English, or readily convertible into English. Our record-keeping guide has the detail.

Where to check each obligation

Where we fit

AUSTRAC's accountant program starter kit is free. AUSTRAC designed it for practices of 15 or fewer personnel that mostly act for Australian-resident individuals, and says a practice outside that profile cannot rely on it to meet AUSTRAC's expectations.⁴

Our kit (A$497, one-off) builds on it. The accountants edition adds a worksheet for deciding which of your engagements are designated, with the section 6(5C) exclusions and AUSTRAC's worked examples, and a tipping-off procedure with the section 123(4) exception written in. Our set-up service (from A$990) tailors it to your practice. We do not act as your compliance officer, lodge reports for you or carry out your independent evaluation.

• Your sector page: accounting practices.
• More guides: the guides page, and every source on our sources page.

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