Tranche 2 essentials

Is my business an AUSTRAC reporting entity? (lawyers, accountants, real estate, conveyancers, jewellers)

AML/CTF capture is about the service you provide, not your job title. Here's how to tell whether your law, accounting, real estate, conveyancing or precious-metals business is an AUSTRAC reporting entity — checked against AUSTRAC guidance.

The single most common mistake we see is a business assuming it's captured (or not) based on its profession. AUSTRAC is explicit: capture is service-based, not occupation-based. You're an AUSTRAC reporting entity only if you provide a "designated service" listed in the AML/CTF Act and there's a geographical link to Australia. (Source: AUSTRAC — professional designated services.)

So the real question isn't "am I a lawyer?" — it's "do I provide a designated service?" Here's how each sector is captured.

Real estate agents and buyer's agents

The designated service is brokering the purchase, sale or transfer of real estate as agent, for compensation. A seller's agent starts providing the service when an agreement to broker the sale is signed; service to the buyer begins when it's reasonably expected the transaction will proceed (typically when the offer is accepted and the contract is signed). You must have your AML/CTF program in place before you broker. (Source: AUSTRAC — real estate designated services.) There's more in What real estate agents need for AML/CTF compliance.

Lawyers and conveyancers

The core trigger is planning or executing a transaction for the sale, purchase or transfer of real estate for a client — both the planning and the execution are captured. That includes preparing or lodging the contract of sale and transfer instrument, researching titles, and coordinating payments and mortgage discharge with financial institutions. (Source: AUSTRAC — professional designated services.)

Accountants

Accountants are captured by more than just handling client money. Designated services include assisting to plan or execute transactions to buy, sell or transfer real estate or a body corporate; receiving, holding, controlling or managing a client's money, accounts, securities or property as part of a transaction; organising equity or debt financing for a body corporate; selling shelf companies; creating or restructuring companies or trusts; acting as (or arranging) a nominee director, secretary, trustee or partner; and providing a registered office address. Importantly, AUSTRAC says **general tax or accounting advice that only influences a possible transaction is not automatically captured** — the service must directly advance the relevant transaction. (Source: AUSTRAC — professional designated services.) See What accountants need for AML/CTF compliance.

Handling client money or property

A standalone designated service captures professionals who receive, hold, control or manage a person's money or property — including where it passes through a trust account or where you act on the client's direction. Examples: managing sale proceeds in escrow, holding money before it settles as trust property, or having authority to make payments from a customer's bank account. (Source: AUSTRAC — professional designated services.)

Dealers in precious metals and stones

The designated service is buying or selling precious metals, stones or products for A$10,000 or more in physical currency (cash) and/or virtual assets — including where linked transactions are deliberately split to fall under $10,000. A key qualifier: transactions made only by debit/credit card or bank transfer are not a designated service. Precious metals include gold, silver, platinum and related metals (or alloys ≥2% by weight); precious stones include diamonds, pearls and opals. (Source: AUSTRAC — precious metals, stones and products designated services.)

The geographical link

Even if you provide a listed service, obligations only apply if there's a geographical link to Australia — broadly, the service is provided at or through a permanent establishment in Australia, or by an Australian resident / qualifying Australian subsidiary through a permanent establishment overseas. (Source: AUSTRAC — geographical link requirement.)

Still not sure?

Some activities look adjacent to a designated service but aren't one — see What is NOT a designated service for the common exclusions. If you provide a designated service with a geographical link to Australia, the next step is your risk assessment.

General information only. Capture is fact-specific. This reflects AUSTRAC guidance current to June 2026 and is not legal advice — confirm your position with AUSTRAC (austrac.gov.au) or a qualified adviser.

Run the free ML/TF risk assessment →