AML/CTF compliance for accounting firms — AUSTRAC Tranche 2 from July 2026

Yes. The AML/CTF Amendment Act 2024 extends the AML/CTF regime to accountants providing designated services from 1 July 2026. Designated accounting services include forming companies or trusts on behalf of clients, acting as a nominee director, managing client money, and acting for a client in real property transactions. Pure tax return preparation and financial statement audits are generally outside scope, but most mid-size firms provide at least one captured service.

Yes. Under s 81 of the AML/CTF Act 2006 (Cth), each reporting entity — defined by its legal identity — must have its own board-adopted AML/CTF program that reflects its specific designated services and risk profile. A group template or firm-wide policy does not substitute for an entity-specific program. For accounting firms managing compliance for multiple clients, this means generating a separate program for each entity.

Under the AML/CTF Amendment Act 2024, designated accounting services include: forming a company, partnership, or trust on behalf of a client; acting as a nominee director, secretary, or shareholder; managing client money, securities, or other assets; and acting for a client in a real property transaction. Bookkeeping of the client's own accounts and preparing financial statements are generally not captured, but firms should review their complete service list against the amended Table 2 of s 6.

No. AUSTRAC requires each reporting entity's program to reflect that entity's specific risk profile — its designated services, customer types, delivery channels, and geographic exposure. A single template shared across clients contradicts this requirement. However, an accounting firm can use a systematic platform (like AutoAML) to generate entity-specific programs efficiently from structured questionnaire inputs.

Under Part 2 of the AML/CTF Act and Chapter 4 of the AML/CTF Rules, CDD must be conducted before or at the point a customer first accesses a designated service. For individual clients, this means verifying name, date of birth, and residential address. For corporate and trust clients, it extends to identifying beneficial owners — anyone who ultimately owns or controls 25% or more. Enhanced CDD applies for high-risk customers such as politically exposed persons (PEPs) or clients from high-risk jurisdictions.

Under s 41 of the AML/CTF Act, a Suspicious Matter Report must be lodged with AUSTRAC within 3 business days (or 24 hours for terrorism-financing suspicion) when you have reasonable grounds to suspect a transaction involves proceeds of crime, money laundering, or terrorism financing. SMR obligations apply to the firm's own designated services — not, generally, to information learned purely through the provision of advice. Tipping off the customer about an SMR is a criminal offence.