See exactly what you're buying.

ML/TF and Proliferation Financing Risk Assessment

AML/CTF Program — Accounting Practice Edition

Document reference: AML-RA-001Practice name: [Practice Name]ABN: [ABN]Principal/Governing Body: [Governing Body — e.g., Director(s) / Board / Practice Principal]AML/CTF Compliance Officer: [Compliance Officer Full Name]Date of this assessment: [Date]Next scheduled review: [Date — at minimum annually, or upon material change]Version: 1.0

IMPORTANT — LEGAL NOTICE

This document is a done-for-you template to assist [Practice Name] in meeting its AML/CTF program obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) as reformed by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth).

It is general compliance support material only. It does not constitute legal advice. This document is not affiliated with, produced by, or endorsed by AUSTRAC or any government body. Whether [Practice Name] satisfies its obligations under the AML/CTF Act depends entirely on how this document is implemented, maintained, and reviewed by [Practice Name]. No outcome — including avoiding regulatory action — is promised or implied.

You must implement this assessment in good faith, train relevant staff, keep it current, and obtain legal advice if uncertain about your obligations. Membership of CPA Australia, CA ANZ, IPA or TPB registration does not substitute for AUSTRAC compliance obligations.

This document reflects AUSTRAC guidance and legislation as at June 2026. Regulatory guidance for newly regulated sectors continues to be published. Confirm current requirements with AUSTRAC at austrac.gov.au before relying on any specific obligation described here.

1. Purpose and Regulatory Context

1.1 Why this document exists

The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) extended Australia's AML/CTF regime to accountants, bookkeepers and registered tax agents from 1 July 2026, when those professionals provide the newly specified designated services. From that date, [Practice Name] is a reporting entity under the AML/CTF Act in respect of each designated service it provides.

Under the reformed AML/CTF program requirements, every reporting entity must:

1. Conduct and document an ML/TF and proliferation financing risk assessment — this document.
2. Develop and maintain AML/CTF policies, procedures, systems and controls that address the risks identified here.
3. Arrange a periodic independent evaluation of the entire AML/CTF program.

The previous "Part A / Part B" program structure has been replaced by the reforms. This assessment is a core component of the reformed AML/CTF program.

Source: austrac.gov.au/about-us/amlctf-reform/summary-amlctf-obligations-tranche-2-entities

1.2 Scope of this assessment

This assessment covers the ML/TF and proliferation financing risks faced by [Practice Name] when providing the following designated services under the AML/CTF Act. The designated services listed below reflect AUSTRAC's published guidance for accountants as at the date of this kit. Confirm the current designated-service categories in AUSTRAC Online when you enrol — see austrac.gov.au/new-austrac/designated-services-newly-regulated-entities/professional-designated-services for the latest descriptions.

Designated services for accountants (as captured by Tranche 2):

#

Designated service

Notes

DS1

Assisting a client to plan or execute a transaction involving the buying, selling or transfer of real estate, or of a body corporate

Includes advising on structuring a property acquisition through a company or trust

DS2

Managing a client's money, accounts, securities or other assets

Includes operating trust accounts, managing investment portfolios, or holding client funds

DS3

Customer Due Diligence (CDD) Procedure

AML/CTF Program — Accountants, Bookkeepers & Tax Agents Edition

Document reference: AML-CDD-003Practice name: [Practice Name]ABN: [ABN]Principal/Governing Body: [Governing Body — e.g., Principal(s) / Partners / Director(s)]AML/CTF Compliance Officer: [Compliance Officer Full Name]Date adopted: [Date]Next scheduled review: [Date — at minimum annually, or upon material change]Version: 1.0

IMPORTANT — LEGAL NOTICE

This document is a done-for-you template to assist [Practice Name] in meeting its AML/CTF program obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) as reformed by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth).

It is general compliance support material only. It does not constitute legal advice. This document is not affiliated with, produced by, or endorsed by AUSTRAC, CPA Australia, CA ANZ, the IPA, the Tax Practitioners Board, or any Australian government or professional body. Whether [Practice Name] satisfies its obligations under the AML/CTF Act depends entirely on how this document is implemented, maintained, reviewed, and operationalised by [Practice Name] and its staff. No outcome — including avoiding regulatory action — is promised or implied.

Replace all [merge fields] with your practice's details before use. Confirm current requirements with AUSTRAC at austrac.gov.au or with a qualified Australian lawyer before relying on any item in this document. Requirements may change after publication.

Sources: austrac.gov.au — "Your obligations"; "Customer due diligence"; "Assigning customer risk ratings"; "New industries and services to be regulated"; austrac.gov.au/new-austrac/designated-services-newly-regulated-entities/

Table of Contents

1. Purpose and Scope
2. When CDD Is Required
3. Who Must Be Identified and Verified
4. CDD Risk Tiers — Standard, Enhanced and Simplified
5. Identifying and Verifying Individual Clients
6. Identifying and Verifying Company Clients — Including Beneficial Owners
7. Identifying and Verifying Trust Clients — Including Beneficial Owners
8. Politically Exposed Persons (PEPs)
9. Sanctions Screening
10. Source of Funds and Source of Wealth
11. Ongoing CDD and Monitoring
12. CDD Failure — What to Do When CDD Cannot Be Completed
13. Third-Party Intermediaries and Reliance Arrangements
14. Offshore Clients and Foreign-Connected Structures — Additional Steps
15. CDD Record-Keeping
16. CDD Checklist — Frontline Reference
17. Sign-Off Block

1. Purpose and Scope

1.1 Purpose

This procedure sets out how [Practice Name] identifies and verifies its clients — and, where applicable, the beneficial owners behind those clients — when providing designated accounting, bookkeeping, or tax-agent services under the AML/CTF Act.

Customer due diligence (CDD) is sometimes called "Know Your Customer" (KYC) or, in a professional-services context, "Know Your Client." Its purpose is to ensure [Practice Name]:

Enhanced Customer Due Diligence (ECDD) — High-Risk Clients and Situations

Document 04 — Accounting Practice Edition

Practice Name: [Practice Name]ABN: [ABN]AML/CTF Compliance Officer: [Compliance Officer]Document Version: 1.0Effective Date: [Date — must be on or before 1 July 2026]Last Reviewed: [Date]Next Scheduled Review: [Date — recommend annually, or after material business change or AUSTRAC guidance update]

IMPORTANT DISCLAIMER

This document is an independent compliance support product. It is not affiliated with, endorsed by, or approved by AUSTRAC, the Attorney-General's Department, CPA Australia, CA ANZ, IPA, the Tax Practitioners Board, or any Australian government body. Nothing in this document constitutes legal advice. This is a starting-point template that [Practice Name] must read, adapt to its specific circumstances, implement, and actively maintain. Compliance outcomes depend on the quality of your implementation, governance, training, and ongoing monitoring — not on the existence of this document. No outcome is promised or implied, including freedom from regulatory action. For legal advice about your specific obligations, engage a qualified Australian lawyer with AML/CTF expertise.

Table of Contents

1. Purpose and Scope
2. Legislative Framework and Context
3. ECDD Trigger Checklist
4. PEP Determination Flow
5. ECDD for Politically Exposed Persons (PEPs)
6. ECDD for Offshore Clients and Offshore-Directed Instructions
7. ECDD for Opaque and Complex Ownership Structures
8. ECDD for Higher-Risk Jurisdictions
9. Source-of-Funds and Source-of-Wealth Checks
10. Senior Management Approval
11. The Decision to Proceed
12. Documentation and Record-Keeping
13. Ongoing Monitoring of High-Risk Clients
14. Sign-Off Block

1. Purpose and Scope

1.1 Purpose

This document sets out [Practice Name]'s Enhanced Customer Due Diligence (ECDD) procedure. ECDD is the intensified due diligence required when a client, engagement, or business relationship is assessed as high risk for money laundering (ML), terrorism financing (TF), or proliferation financing (PF).

Standard customer due diligence (initial and ongoing CDD — Document 03) is the baseline for all clients. ECDD adds additional layers of scrutiny, documentation, and authorisation on top of that baseline. It does not replace standard CDD — it supplements it.

The purpose of ECDD is to:

Ensure [Practice Name] has a clear, documented understanding of who it is dealing with before providing a designated service to a high-risk client.

Suspicious Matter Reporting (SMR) Procedure and Internal Template

AML/CTF Program — Accountants, Bookkeepers & Tax Agents Edition

Document reference: AML-SMR-006Practice name: [Practice Name]ABN: [ABN]Principal/Governing Body: [Governing Body — e.g., Principal(s) / Partners / Director(s)]AML/CTF Compliance Officer: [Compliance Officer Full Name]Date adopted: [Date]Next scheduled review: [Date — at minimum annually, or upon material change]Version: 1.0

IMPORTANT — LEGAL NOTICE

This document is a done-for-you template to assist [Practice Name] in meeting its AML/CTF program obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) as reformed by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth).

It is general compliance support material only. It does not constitute legal advice. This document is not affiliated with, produced by, or endorsed by AUSTRAC, CPA Australia, CA ANZ, the IPA, the Tax Practitioners Board, or any Australian government or professional body. Whether [Practice Name] satisfies its obligations under the AML/CTF Act depends entirely on how this document is implemented, maintained, reviewed, and operationalised by [Practice Name] and its staff. No outcome — including avoiding regulatory action — is promised or implied.

Replace all [merge fields] with your practice's details before use. Confirm current AUSTRAC guidance for any operational detail that may have changed since this template was prepared — refer to austrac.gov.au for authoritative and up-to-date requirements.

Tipping-off warning: Do not disclose the contents of any SMR, or the fact that an SMR has been or may be submitted, to the person who is the subject of the report, or to any other person, except as permitted by law. Under the reformed AML/CTF Act (as amended from 31 March 2025), tipping off is a criminal offence where disclosure would or could reasonably be expected to prejudice an investigation. This warning applies to all staff and management at all times — including after the engagement has ended.

Sources: austrac.gov.au — "Your obligations"; "Suspicious matter reporting"; "How to submit a suspicious matter report"; AUSTRAC guidance on accountants and bookkeepers as newly regulated entities.

Table of Contents

1. Purpose and Scope
2. What Is a Suspicious Matter?
3. Accounting Practice Red Flags and Typologies
4. How Staff Identify and Escalate Concerns
5. The Compliance Officer's Assessment Process
6. When and How to Submit an SMR to AUSTRAC
7. Tipping-Off — What It Is and Why It Matters
8. Handling the Engagement While an SMR Is Under Consideration
9. Record-Keeping for SMRs
10. Staff Training and Awareness
11. Internal SMR Escalation Form (Appendix A)
12. Internal SMR Register Template (Appendix B)
13. Sign-Off Block

1. Purpose and Scope

1.1 Purpose

This procedure sets out how [Practice Name] identifies suspicious matters arising in the course of providing designated accounting, bookkeeping, or tax-agent services, how staff escalate concerns to the AML/CTF Compliance Officer, and how the Compliance Officer decides whether to submit a Suspicious Matter Report (SMR) to AUSTRAC.

SMRs are one of [Practice Name]'s most important obligations as a reporting entity. They form part of Australia's financial intelligence infrastructure. When an accounting practice submits an SMR, AUSTRAC may analyse the information and share it with law enforcement agencies including the Australian Federal Police, state police forces, the Australian Taxation Office, and other regulatory bodies. A well-prepared, timely SMR helps protect the integrity of Australia's business and financial system and discharges [Practice Name]'s legal obligations.

This procedure does not ask staff to be investigators or to draw legal conclusions. Staff are asked to notice and report internally whenever a client, transaction, or engagement circumstance feels wrong. The Compliance Officer then assesses whether an SMR is required.

Beneficial Ownership & Control Identification Form

Practice / Agency Name: [Practice/Agency Name]ABN: [ABN]Compliance Officer: [Compliance Officer]Form Reference: [Form Reference Number]

1. Purpose and Scope

This form is used to identify and verify every individual who is a beneficial owner or controller of a client entity (company, trust, partnership, or other structure). It must be completed for each relevant client before, or as early as practicable after, a designated service commences.

Designated services in scope for this practice include:

1. Forming or restructuring a company or trust.
2. Acting as, or arranging, a nominee director, secretary, trustee, or shareholder.
3. Providing a registered office or business address.
4. Managing client money, assets, or securities.
5. Assisting to buy or sell a business or legal entity.

Complete a separate form for each distinct legal entity or trust structure associated with the client engagement.

2. Client Entity Details

Field

Details

Client / Entity Legal Name

[Client Entity Legal Name]

Trading Name (if different)

[Trading Name]

Entity Type

[Company / Trust / Partnership / Other — specify]

ACN / ABN / ARBN

[ACN/ABN/ARBN]

Registered Address

[Registered Address]

Principal Place of Business

[Principal Place of Business]

AML/CTF Compliance Calendar & Obligations Register

Practice/Agency Name: [Practice/Agency Name]ABN: [ABN]Compliance Officer: [Compliance Officer Name]Register Period: [Financial Year / Date Range]Last Reviewed: [Date]Next Scheduled Review: [Date]

1. Purpose

This register records every recurring AML/CTF obligation imposed on [Practice/Agency Name] under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the associated Rules, as amended by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) (Tranche 2 reforms, commencing 1 July 2026).

The register is designed to:

give the Compliance Officer a single, dated checklist of all recurring obligations;

ensure no obligation is missed between reporting periods;

provide an audit trail that demonstrates the practice took its compliance duties seriously; and

flag when AUSTRAC guidance changes require a corresponding update to this document or to internal procedures.

This register must be reviewed and updated at least annually, and promptly whenever AUSTRAC publishes new or revised guidance that affects any obligation listed below.

Restricted document. Access is limited to the Compliance Officer, principals, and individuals expressly authorised in writing by the Compliance Officer.

2. Designated Services in Scope

[Practice/Agency Name] provides one or more of the following designated services, each of which triggers obligations under the AML/CTF regime:

Forming or restructuring companies, trusts, or other legal structures.

Acting as, or arranging, a nominee director, secretary, trustee, or shareholder.

Providing a registered office or business address to clients.

Managing client money or assets.

Assisting to buy or sell a business or legal entity.

Confirm the complete list of designated services with reference to the Designated Service Determination Worksheet (Document 14 of this kit) and against austrac.gov.au before finalising this register.

3. Red-Flag Context Relevant to This Practice

The following risk indicators are particularly relevant given the designated services above. They inform the frequency and depth of many obligations in Section 5.

Opaque or unnecessarily complex corporate or trust structures.

Use of nominee directors, secretaries, trustees, or shareholders without clear commercial rationale.

False or inflated invoicing arrangements.