For Accountants
AML/CTF Compliance for Australian Accounting Practices
From 1 July 2026, Australian accountants providing designated services fall under AUSTRAC's AML/CTF regime. AML SoftServe gives your firm the program, workflows and Compliance Officer support to enrol on time and stay compliant.
What changed on 1 July 2026
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024extended AUSTRAC's regime to Tranche 2 professions, including accounting practices that provide designated services. Enrolment opened 31 March 2026, obligations commenced 1 July 2026, and firms already providing designated services on that date must enrol with AUSTRAC by 29 July 2026.
Which accountants are captured?
You're captured if your practice provides any of these AUSTRAC-designated services in the ordinary course of business:
- Setting up companies, trusts or SMSFs for clients
- Acting as trustee, director or company secretary for client entities
- Providing a registered office address for clients
- Buying, selling or transferring shares in client-facing structures
- Managing client money, securities or other assets held in trust
- Assisting with real property transactions (buying, selling, transferring)
- Restructuring or reorganising client business entities
- Providing services in connection with buying or selling a business
Tax return preparation and bookkeeping alone are not designated services. But most mid-sized firms cross the line the moment they help a client stand up a trust or a company — which is why we recommend a designated-services audit before enrolling.
What your practice must do
Enrol via AUSTRAC Online
You will need your ABN, professional body memberships (CPA / CA ANZ / IPA / NTAA), a list of the designated services your practice offers, and your Compliance Officer’s details. Existing practices already providing designated services on 1 July 2026 must enrol by 29 July 2026. New practices enrol within 28 days of the first captured engagement — typically the day you first help a client set up a trust or a company.
Document a practice-specific AML/CTF Program
Your program must reflect the actual services you offer — trust setup, SMSF administration, company formations, nominee director/secretary roles, real property advice, share transactions. Generic templates rarely survive an AUSTRAC review. Cover governance (who is your CO and their reporting line), risk assessment segmented by service line, CDD procedures, transaction monitoring, staff training and independent evaluation every 3 years.
Run CDD before providing the service
Every new engagement for a designated service triggers CDD before delivery, not after. That means verifying identity and, where the client presents or asks you to set up a corporate or trust structure, capturing every beneficial owner at the 25 percent threshold plus controlling persons. Trust deeds, ASIC extracts, individual ID for beneficiaries. Refresh on trigger events like a change of directors, new appointors, or an amendment to the trust deed.
Segment your Risk Mitigation Plan by service line
Rate ML/TF risk across the client book by service type (personal tax vs business advisory vs SMSF vs company formation), by ownership complexity (sole trader vs multi-layer corporate vs offshore-controlled), and by payment profile (professional-fee vs cash-adjacent trades). Refresh the RMP when you launch a new service line, take on your first offshore-controlled client, or move into higher-risk sectors like crypto advisory.
Train every partner, manager, senior and admin
Every person who touches a designated service must complete AML/CTF training before their first captured engagement — including seasonal tax-time staff and bookkeepers who onboard clients. Track competency by individual with annual refreshers. Independent evaluators specifically check training coverage for casual and part-time staff, which is where most firms fail.
Report to AUSTRAC on strict timeframes
Suspicious matter reports (SMRs) within 24 hours if terrorism financing is suspected, otherwise within 3 business days once suspicion forms. Threshold transaction reports for physical cash movements of AUD 10,000 or more. Annual compliance report to AUSTRAC by 31 March each year. The tipping-off offence applies — you cannot disclose an SMR to the client, directly or by materially changed conduct.
How AML SoftServe fits an accounting practice
- Pre-built AML/CTF Program with the accounting-services risk taxonomy already coded — trust setup, company formation, SMSF administration, nominee director / secretary services, real property advice and share transactions each mapped to their own risk rating.
- Beneficial-ownership capture tuned for the structures accountants work with daily — unit-trust-over-company, discretionary trust with corporate trustee, SMSF with individual trustees, foreign-controlled Australian sub. Auto-flags when a structure has more layers than the client’s stated purpose warrants.
- Continuous PEP, sanctions and adverse-media screening across your entire client base, not just at engagement. When a director on one of your clients gets added to a sanctions list mid-year, your Compliance Officer sees it within 24 hours.
- Staff training module segmented by role — partners, managers, seniors, admins and seasonal tax-time contractors — so you can prove 100 percent training coverage even for casual staff, the gap where most firms fail an independent evaluation.
- Optional Compliance Officer support — our team runs CDD/EDD end-to-end so your billable senior accountants aren’t burning chargeable hours on ID checks and beneficial-ownership tracing.
- AUSTRAC-review-ready audit trail with 7-year retention — every CDD file, SMR draft, training completion, risk rating change and program version, exportable in one click.
Pricing for accounting firms
Path 1 is $1,250 one-off setup with $0/month platform fee. Path 2 is $90/month with Compliance Officer support. Full detail on the pricing page.
Enrolment deadline is 29 July 2026
Book a 30-minute call — we'll audit which of your services are captured and map an enrolment plan you can execute this week. Or read the full Accountant FAQ.