For Accountants

AML/CTF program for accountants in Australia — AUSTRAC Tranche 2

If your firm forms companies, manages client money, sets up trusts, or transfers real property on behalf of a client, you become a reporting entity on 1 July 2026. AutoAML drafts the 13 required documents from your firm's actual service mix.

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Compliance Challenges for Accountants

From 1 July 2026 accountants providing designated services fall under the AML/CTF Act. Generate your full AUSTRAC-ready program in under 10 minutes.

It's the service, not the title, that triggers obligations

AUSTRAC captures specific 'designated services' — managing client money, forming companies, acting on behalf of a client in property transactions, creating express trusts. Plenty of accountants do at least one without realising it triggers the Act.

Tax-agent obligations don't substitute for AML/CTF compliance

Your TPB Code of Professional Conduct, APES 110 and AUSTRAC's program are three separate regimes with overlapping but distinct documentation. Auditors will expect to see evidence of all three.

Trust accounts and client money are high-risk by default

Accepting client funds for onward payment is a textbook layering channel. AUSTRAC expects threshold transaction reporting for $10,000+ cash equivalents within 10 business days (s 43 of the Act).

Foreign-owned structures need enhanced CDD, not box-ticking

Beneficial-ownership obligations require you to look through trusts and corporate layers to a 25 % controller. PEPs, sanctioned jurisdictions and shell entities all trigger enhanced CDD under Chapter 4 of the AML/CTF Rules.

What Accountants Need for Compliance

The AML/CTF Act 2006 (Cth) and the AML/CTF Rules require all reporting entities to maintain these documents and procedures.

AML/CTF Program covering Part A (risk-based systems) and Part B (CDD) — s 81 of the Act

ML/TF Risk Assessment scoped to the designated services your firm actually provides

Customer Due Diligence procedures aligned with Chapter 4 of the AML/CTF Rules

Suspicious Matter Report (SMR) workflow — 3 business days, 24 hours for terrorism financing

Threshold Transaction Report (TTR) procedure for $10,000+ physical-currency equivalents

Record-keeping aligned with the 7-year retention requirement under s 107

AML/CTF Compliance Officer appointment and reporting line to senior management

Annual independent review and Board-approved staff training program

Deadline & Applicability

Tranche 2 of the AML/CTF reforms commences 1 July 2026. From that date, accountants providing one or more designated services must be enrolled with AUSTRAC, have a Board-adopted program in place, and be operating it day-to-day. The AML/CTF Amendment Act 2024 confirmed the start date.

Last reviewed: 18 April 2026 · Information is general guidance, not legal advice.

How AutoAML Helps Accountants

AI-Generated Documents

All 13 compliance documents drafted from your service mix and risk profile — Part A, Part B, risk assessment, CDD scripts, the lot.

Team & Audit Trail

Invite your team, assign Compliance Officer roles, and keep a tamper-evident audit log AUSTRAC supervisors can read.

SMR & TTR Built-in

Reporting workflows, training tracking, annual review reminders and document version control — so the program stays alive after day one.

Frequently Asked Questions

Accountants & AUSTRAC: common questions

Do all accountants need to comply with AUSTRAC from July 2026?

No — only accountants providing one or more 'designated services' under the amended AML/CTF Act. The triggers include forming companies or trusts, acting as a nominee director, managing client money, and acting for a client in real property transactions. Pure tax return preparation is outside scope.

I'm a sole practitioner. Do I still need a full AML/CTF program?

Yes. The Act applies regardless of firm size if you provide a designated service. Your program can be proportionate to your risk profile, but it still needs to cover Part A and Part B requirements, name a Compliance Officer (which can be you), and be subject to independent review.

How does this interact with my TPB and APES 110 obligations?

They're complementary, not substitutes. The TPB Code, APES 110 (110.1 fundamental principles) and AUSTRAC each impose duties around client identification and reporting, but the AML/CTF program is a separate, documented compliance system that AUSTRAC can audit directly.

What are the penalties for non-compliance?

Civil penalties under the AML/CTF Act run into the tens of millions of dollars per contravention for body corporates. Westpac was penalised $1.3 billion in 2020 and CBA $700 million in 2018 — the regime is enforced, not theoretical.

How long does it take to set up a compliant program?

Manually with consultants, typically 6–12 weeks and $5,000–$25,000 in fees. With AutoAML, a draft of all 13 documents tailored to your service mix is generated in under 10 minutes; expect to spend a few hours reviewing and adopting them.

Do I need to enrol with AUSTRAC before 1 July 2026?

Yes. Enrolment is the first step and is separate from registration (which only certain businesses need). AUSTRAC has indicated guidance and an enrolment portal will be available before the commencement date.

Related industries under AUSTRAC Tranche 2

Many firms work across more than one designated-service category. Check the related sectors below.

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