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Free check · general information, not legal advice

Does the AML/CTF Act reach your business? A six-step check

Last checked 25 September 2026 against the AML/CTF Act compilation C2026C00274, the AML/CTF Rules 2025 (F2025L01026) and the Transitional Rules 2026 (F2026L00393)

The Act turns on the services you provide, not on your job title or the size of your firm. Work through six short steps. Each answer is a link to the next step, or to the Act's own words for the service you picked.

How to use this check. Pick the answer that fits and follow its link. You may provide more than one service, so read every item your answers point to. This is a guide, not a ruling: you decide, and you should confirm the result with AUSTRAC's own Check if you may be regulated tool (opens in a new window).

s 6 the law, read in the authorised textAUSTRAC guidance the regulator's published guidance, which is not law

Which of these describes your business?

Start with your sector. The next step lists the services that sector most often provides.

Which services do you provide?

Read the list for your sector and follow every line that is true for you. Each link opens the Act's wording for that service. Then come back and go to step 3.

Real estate agencies, buyer's agents and developers

Conveyancing practices

Accounting, bookkeeping and tax practices

Any other business

The services above are listed by what is done, not by who does it, so read the other lists too. Dealers in precious metals and stones are covered by a different table: see the dealers guide. If nothing in any list fits, go to none of these apply.

Do you provide the service as part of a business?

Every item in Tables 5 and 6 applies to a service provided "in the course of carrying on a business".1 s 6 Selling your own home, or helping a relative for free, is not carrying on a business.

Do you provide it from a place of business in Australia?

An item applies only if the service is provided at or through a permanent establishment of yours in Australia. It can also apply to an Australian resident, or a subsidiary of an Australian company, that provides it through a permanent establishment overseas.2 s 6(6)

Have you enrolled with AUSTRAC?

How many people work in your business?

Count everyone, including administrative staff.3 The number matters for AUSTRAC's free starter kits, not for whether the Act applies.

The items, in the Act's words

Each card quotes the item from section 6 of the Act, and names the customer the Act gives for it.4 s 6 A card is where the law applies, if your facts match its words. It is not a finding that you are covered.

Real estate

Table 5, item 1: brokering real estate

"brokering the sale, purchase or transfer of real estate on behalf of a buyer, seller, transferee or transferor in the course of carrying on a business"

Customer: both the seller or transferor and the buyer or transferee.

So a buyer's agent is covered, and an agent acting only for the seller still has obligations towards the buyer. A lease for a term of 30 years or less, not counting options to renew, is not "real estate".5 s 5 AUSTRAC: real estate designated services. Our page: real estate agencies.

Back to the list · Go to step 3

Real estate

Table 5, item 2: selling your own real estate

"selling or transferring real estate in the course of carrying on a business selling real estate, where the sale or transfer is not brokered by an independent real estate agent"

Customer: the buyer or transferee.

AUSTRAC's examples include developers selling house and land packages, apartments off the plan and blocks in new subdivisions without an independent agent.6 AUSTRAC AUSTRAC: real estate designated services.

Back to the list · Go to step 3

Professional services

Table 6, item 1: acting in a property transaction

"assisting a person in the planning or execution of a transaction, or otherwise acting for or on behalf of a person in a transaction, to sell, buy or otherwise transfer real estate"

Customer: the person you assist or act for.

It applies where the service is provided in the course of carrying on a business, and the transfer is not under, or the result of, a court or tribunal order. This is the core of conveyancing, by a conveyancer or a law practice. Our pages: conveyancers and legal practices.

Back to the lists · Go to step 3

Professional services

Table 6, item 2: selling or buying a company or trust

"assisting a person in the planning or execution of a transaction, or otherwise acting for or on behalf of a person in a transaction, to sell, buy or otherwise transfer a body corporate or legal arrangement"

Customer: the person you assist or act for.

The same business and court-order conditions apply as for item 1. In AUSTRAC's example, tax advice about selling a company is not item 2 on its own; acting for the client in the sale is.7 AUSTRAC

Back to the lists · Go to step 3

Professional services

Table 6, item 3: holding or managing a client's money or property

"receiving, holding and controlling (including disbursing) or managing a person's: (a) money; or (b) accounts; or (c) securities and securities accounts; or (d) virtual assets; or (e) other property; as part of assisting the person in the planning or execution of a transaction, or otherwise acting for or on behalf of a person in a transaction, in the course of carrying on a business"

Customer: the person.

It does not apply in the cases in s 6(5C). They include payment for your own goods or services; money received or paid under a court or tribunal order; payments to or from a government body, a court or tribunal, or a licensed insurer; and, if you provide no other designated service, payments reasonably incidental to a service that is not designated. The Act's own examples are barristers' fees and property management.8 s 6(5C) AUSTRAC: professional designated services.

Back to the lists · Go to step 3

Professional services

Table 6, item 4: equity or debt financing

"assisting a person in organising, planning or executing a transaction, or otherwise acting for or on behalf of a person in a transaction, for equity or debt financing relating to: (a) a body corporate (or proposed body corporate); or (b) a legal arrangement (or proposed legal arrangement); in the course of carrying on a business"

Customer: the person.

Back to the lists · Go to step 3

Professional services

Table 6, item 5: shelf companies

"selling or transferring a shelf company, in the course of carrying on a business"

Customer: the buyer or transferee.

Back to the lists · Go to step 3

Professional services

Table 6, item 6: creating or restructuring a company or trust

"assisting a person to plan or execute, or otherwise acting on behalf of a person in, the creation or restructuring of: (a) a body corporate …; or (b) a legal arrangement; in the course of carrying on a business"

Customer: the person, and also, when you create a company, its beneficial owners and directors, or, when you create an express trust, its trustee, settlor and beneficiaries.

Registering a company or settling a trust deed for a client is this item. Our page: accounting practices.

Back to the lists · Go to step 3

Professional services

Table 6, item 7: acting as, or arranging, an officer or trustee

"acting as, or arranging for another person to act as, any of the following, on behalf of a person (the nominator), in the course of carrying on a business: (a) a director or secretary of a company; (b) a power of attorney of a body corporate or legal arrangement; (c) a partner in a partnership; (d) a trustee of an express trust"

Customer: the nominator.

It also covers a functionally equivalent position in any other legal arrangement. It does not cover a fiduciary role under a court or tribunal order, or acting as trustee of a regulated debtor's estate in bankruptcy.9 s 6(5E)

Back to the lists · Go to step 3

Professional services

Table 6, item 8: nominee shareholders

"acting as, or arranging for another person to act as, a nominee shareholder of a body corporate or legal arrangement, on behalf of a person (the nominator), in the course of carrying on a business"

Customer: the nominator.

Back to the lists · Go to step 3

Professional services

Table 6, item 9: registered office or business address

"providing a registered office address or principal place of business address of a body corporate or legal arrangement, in the course of carrying on a business"

Customer: the person to whom the service is provided.

This is the item most often missed by accounting practices that let clients use the office address.

Back to the lists · Go to step 3

What your other answers mean

Close to the line

These are not listed services on their own:

  • Tax returns, BAS, payroll and bookkeeping. None is an item of Table 6.4 In AUSTRAC's bookkeeper example, routine payments made on a client's fixed instructions are less likely to be "managing" money under item 3, and are generally reasonably incidental to the bookkeeping, and so excluded, if the practice provides no other designated service.7 AUSTRAC
  • Leases and property management. A lease of 30 years or less is not real estate.5 s 5 The Act names property management as an example of a payment excluded from item 3.8 s 6(5C)
  • Barristers. A barrister's service on a solicitor's instructions, given in connection with a designated service, is not itself a designated service.10 s 6(6B)
  • Court orders. Items 1 and 2 of Table 6 do not apply to a transfer under, or resulting from, a court or tribunal order. AUSTRAC's view is that litigation will generally fall outside Table 6.7 AUSTRAC

If you also provide any listed service, that service is covered. More: what is not a designated service.

None of these apply

Then, on your answers, you do not provide a designated service and need not enrol. AUSTRAC expects a business that decides it is not regulated to be able to explain why. If you are not certain, it expects a record of the services you considered, why you concluded they are not designated services, the AUSTRAC guidance you relied on and any legal advice you used.11 AUSTRAC Date the note, and look at it again whenever you add a service.

No place of business in Australia

If none of the limbs in s 6(6) applies, the items in Tables 5 and 6 do not apply to the service.2 s 6(6) Cross-border cases are fact-specific: take legal advice before you rely on this.

Not enrolled yet

If you were already providing a Table 5 or Table 6 service when the obligations started on 1 July 2026, enrolment was due by 29 July 2026. If you started later, you must apply within 28 days of first providing it.12 s 51B(1)

The obligation does not lapse. It continues until you apply, and each day after the deadline is a separate contravention.12 s 51B Not enrolling can also lead to an infringement notice of 60 penalty units for a body corporate or 12 for anyone else.13 s 186A On 28 August 2026 AUSTRAC said it had begun issuing section 167 notices to businesses that appear to provide designated services without enrolling.14 AUSTRAC

You enrol directly with AUSTRAC, and you do not need to buy anything from us to do it: Enrol with AUSTRAC (opens in a new window). Our enrolment guide explains the form.

Go to step 6

15 or fewer people

AUSTRAC publishes free program starter kits, release 1.1 of 10 June 2026. For accounting practices, real estate businesses and legal practices, one of the suitability criteria is 15 or fewer personnel. Others include mostly Australian-resident individual clients, no overseas property work, no fully remote self-service onboarding, and not being part of a large reporting group.3 AUSTRAC Check the conveyancer kit's own criteria on AUSTRAC's site.

Outside that profile, AUSTRAC says you cannot rely on the starter kit to meet its regulatory expectations.3 Our kit (A$497) and Set-up service (from A$990) are built on those starter kits, so the same profile applies to them.

16 or more people

AUSTRAC's starter kits for accounting practices, real estate businesses and legal practices are designed for 15 or fewer personnel. Outside the profile, AUSTRAC says you cannot rely on the starter kit to meet its regulatory expectations.3 AUSTRAC Our kit and Set-up service are built on the starter kits, so they are not designed for your firm. You need a program built for your business, with advice from a lawyer or an AML/CTF adviser.

This is a guide. You decide.

This check maps your answers to the wording of the Act. It is not a ruling, and it is not legal advice. Whether a service you provide is a designated service is your decision, made on the Act and AUSTRAC's guidance. Check your answer with AUSTRAC's own tool: Check if you may be regulated (opens in a new window). If your case is doubtful, ask a lawyer.

See the kit — A$497Set-up service — from A$990

Independent. Not affiliated with, or endorsed by, AUSTRAC or the Australian Government.

Sources

Law is quoted from the authorised text on the Federal Register of Legislation, opened 25 September 2026. AUSTRAC pages are guidance, not law. They open in a new window, and linking to them does not mean AUSTRAC endorses this page.

  1. Anti-Money Laundering and Counter-Terrorism Financing Act 2006 s 6(5A) (Table 5) and s 6(5B) (Table 6), compilation C2026C00274. legislation.gov.au/C2006A00169/latest/text

  2. AML/CTF Act s 6(6).

  3. AUSTRAC, program starter kits, "Getting started" pages for the accountant, real estate and legal profession kits, release 1.1, 10 June 2026 (guidance). The kits "are not a substitute for legal advice". austrac.gov.au

  4. AML/CTF Act s 6, Tables 5 and 6. The quotations on this page are the item wording; the customer column is summarised.

  5. AML/CTF Act s 5, definition of "real estate". AUSTRAC, "Real estate designated services" (guidance): leases of 30 years or less are not real estate.

  6. AUSTRAC, "Real estate designated services" (guidance). austrac.gov.au

  7. AUSTRAC, "Professional designated services", worked examples (guidance). austrac.gov.au

  8. AML/CTF Act s 6(5C) and (5D), including the note to s 6(5C).

  9. AML/CTF Act s 6(5E).

  10. AML/CTF Act s 6(6B).

  11. AUSTRAC, "Check if you may be regulated", record keeping (guidance). austrac.gov.au

  12. AML/CTF Act s 51B(1), (2B) and (2C). AML/CTF Amendment Act 2024 (C2024A00110), Schedule 3, item 12. legislation.gov.au/C2024A00110/latest/text

  13. AML/CTF Act ss 184(1A) and 186A(1)–(2).

  14. AUSTRAC, "AUSTRAC issues notices to non-enrolled businesses", 28 August 2026 (guidance). austrac.gov.au

Questions

Is this an official determination?

No. It is a plain-English map from your answers to the wording of Tables 5 and 6 in section 6 of the Act. AUSTRAC's own tool and pages are the official guidance, and the Act decides. Where your case is doubtful, take legal advice.

Do you store my answers?

No. There is no form on this page. Each answer is an ordinary link to another part of the same page, so nothing you choose is sent to us.

What if none of the items apply?

Then, on your answers, you do not provide a designated service and need not enrol. AUSTRAC expects a business that decides it is not regulated to be able to explain why, so keep a dated note of the services you considered and your reasons. Check again when your services change.