Why are accountants now covered?
Australia's Financial Action Task Force (FATF) mutual evaluation identified accountants as high-risk for money laundering facilitation. Criminals use accounting services to create corporate structures, manage trust accounts, and move money through legitimate-looking transactions. The Tranche 2 reforms bring Australia in line with international standards — most other FATF countries already regulate accountants for AML.
This doesn't mean your clients are criminals. It means you need systems in place to identify and report suspicious activity — just like banks have had for years.
Which services are covered?
Not all accounting work triggers AML obligations. You only need to comply when providing “designated services,” which include:
- Managing client money or assets — holding funds in trust accounts, managing investment portfolios on behalf of clients
- Company and trust formation — setting up companies, trusts, or other legal entities for clients
- Buying or selling businesses — acting on behalf of clients in acquiring or disposing of business interests
- Financial transaction facilitation — arranging loans, managing financial accounts, or transferring funds
- Tax advisory on structures — advising on arrangements primarily designed to manage assets or facilitate transactions (not standard tax return preparation)
Standard tax return preparation, BAS lodgement, and general bookkeeping are NOT designated services and do not trigger AML obligations on their own. However, if you also provide any of the services above — even occasionally — you are covered.
What you need to do
Step 1: Determine if you provide designated services
Review the list above carefully. Many sole practitioner accountants who only do tax returns and BAS may not be covered. But if you set up companies or trusts for clients, manage trust accounts, or facilitate financial transactions, you are a reporting entity. Use our free compliance check to find out in 30 seconds.
Step 2: Enrol with AUSTRAC
If you provide designated services, you must enrol with AUSTRAC. The 29 July 2026 deadline for existing providers has passed — if you are not yet enrolled, do it now. Enrolment is free and done online through the AUSTRAC portal.
Step 3: Create your AML/CTF program
Your program must include a risk assessment specific to your practice, customer identification procedures, ongoing monitoring processes, and an employee training plan. AUSTRAC provides a “Starter Kit” for accountants — a template-based approach that you can adapt to your business.
AML Mate automates this entire process. Answer questions about your practice and we generate a complete, tailored AML/CTF program using AUSTRAC's official templates.
Step 4: Implement CDD for your clients
Before providing any designated service to a client, you must verify their identity. For individual clients, this means collecting government-issued photo ID. For company or trust clients, you also need to identify beneficial owners (anyone who ultimately owns or controls 25% or more).
You must also screen clients against the DFAT consolidated sanctions list and check for Politically Exposed Persons (PEPs). Higher-risk clients — such as those in cash-intensive industries, those from high-risk jurisdictions, or PEPs — require Enhanced Due Diligence.
Step 5: Know your reporting obligations
As a reporting entity, you must file:
- Suspicious Matter Reports (SMRs) — within 24 hours of forming a suspicion that a client is involved in money laundering, terrorism financing, or other serious crime
- Threshold Transaction Reports (TTRs) — within 10 business days for any cash transaction of $10,000 or more
Reports are filed through AUSTRAC Online. There is a legal protection (“tipping off” provisions) — you must not tell your client that you have filed or intend to file an SMR.
Common concerns from accountants
“I only do tax returns — do I still need to comply?”
If you only prepare tax returns and BAS, you are likely not covered. But review carefully — if you ever set up a company, manage a trust account, or advise on financial structures, you are.
“Won't this scare away my clients?”
Collecting ID is standard practice in banking and real estate. Most clients understand and expect it. Frame it as a regulatory requirement — “As part of new government regulations, we need to verify your identity before we can proceed.”
“How much will this cost me?”
Compliance consultants typically charge $3,000–$10,000 to create an AML/CTF program for an accounting practice. AML Mate starts at $49/month for the full platform including ongoing client management.