⚡ Direct Answer: Accountants in Australia are not currently required to comply with AML/CTF obligations for most standard accounting services. However, the Tranche 2 AML/CTF reforms — commencing 1 July 2026 — will bring accountants and other gatekeeper professions within the AML/CTF regime for the first time. Accounting firms providing designated services from that date must enrol with AUSTRAC by 29 July 2026.
The Current Position: Are Accountants Captured?
Under the existing AML/CTF regime, most traditional accounting services — such as preparing financial statements, lodging tax returns, or providing business advisory services — are not “designated services” under the AML/CTF Act. This means the majority of accounting firms have not historically had formal AML/CTF obligations.
However, this does not mean accountants are completely outside the financial crime risk landscape. AUSTRAC and law enforcement agencies have long recognised that professional service providers can be used — knowingly or unknowingly — to facilitate money laundering. This is why Australia has joined over 30 other countries in expanding AML/CTF obligations to gatekeeper professions.
What Changes Under the Tranche 2 Reforms?
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 introduces significant changes to the AML/CTF regime. The reforms extend the definition of “designated services” to include certain services provided by accountants, lawyers, conveyancers, real estate agents, and trust and company service providers.
For accountants, the new designated services expected to trigger AML/CTF obligations from 1 July 2026 include services related to:
- Buying and selling real estate on behalf of a client
- Managing client money, securities, or other assets
- Opening or managing bank, savings, or securities accounts
- Organising contributions for the creation, operation, or management of companies
- Creating, operating, or managing trusts or similar structures
- Providing registered agent services for companies
- Providing company secretary or nominee services
Accountants providing any of these services from 1 July 2026 will be required to enrol with AUSTRAC and comply with full AML/CTF obligations, including maintaining an AML/CTF program, conducting customer due diligence, and reporting to AUSTRAC.
The Enrolment Deadline for Accountants
Newly regulated businesses — including accountants providing new designated services — must apply to enrol with AUSTRAC by 29 July 2026 (28 days after the commencement date of 1 July 2026). Failure to enrol before providing designated services is itself a breach of the Act.
AUSTRAC has made it clear that it expects newly regulated entities to begin preparing well in advance of this deadline — not simply scramble to enrol at the last minute.
What AML/CTF Obligations Will Accountants Have?
Once captured, accounting firms will need to meet the full suite of AML/CTF obligations applicable to reporting entities, including:
- ML/TF Risk Assessment: Identify and document the money laundering and terrorism financing risks specific to your firm, clients, services, and geographies.
- AML/CTF Program: Develop a written program approved by a senior manager, tailored to your firm’s risk profile, with policies, procedures, and controls.
- Customer Due Diligence (CDD): Verify the identity of clients before providing designated services. Conduct ongoing monitoring of existing client relationships.
- Politically Exposed Persons (PEPs) and Sanctions Screening: Check whether clients are PEPs or subject to targeted financial sanctions.
- Suspicious Matter Reporting (SMR): Report any suspicions of money laundering or terrorism financing to AUSTRAC.
- Record Keeping: Maintain records of CDD, transactions, and program documentation for at least 7 years.
- Staff Training: Ensure employees are trained on AML/CTF obligations and internal procedures.
- Independent Review: Conduct periodic independent evaluations of the AML/CTF program.
Risk Areas for Accountants Right Now
Even before the 2026 reforms take effect, accountants face indirect AML/CTF exposure in certain circumstances. AUSTRAC’s guidance notes that professional service providers can be misused as gatekeepers to the financial system. Accountants should be aware of the following risk indicators:
- Clients requesting assistance with complex financial structures with no clear commercial rationale
- Clients who are evasive about the source of funds or the purpose of transactions
- Requests to handle client funds in unusual ways, including large cash transactions
- Corporate structures that appear designed to obscure beneficial ownership
- Clients in high-risk industries or jurisdictions
- Unexplained wealth or assets inconsistent with known business activities
While reporting obligations may not yet apply, accountants who knowingly assist in money laundering can face criminal liability under other laws. Documenting concerns and seeking legal advice is always prudent.
How Accounting Firms Should Prepare Now
- Assess your services: Review the full list of new designated services and determine which (if any) your firm provides or plans to provide from 1 July 2026.
- Conduct a gap analysis: Compare your current policies against what will be required under the AML/CTF regime.
- Develop an AML/CTF program: Begin drafting a risk-based program that covers your firm’s specific client base and services.
- Implement CDD procedures: Design processes for identifying and verifying clients and screening for PEPs and sanctions.
- Train your staff: Ensure partners and staff understand AML/CTF obligations and can identify suspicious behaviour.
- Enrol with AUSTRAC: Submit your enrolment application before 29 July 2026.
Frequently Asked Questions
Do all accountants need to enrol with AUSTRAC?
No — only accountants who provide the new designated services from 1 July 2026. If your firm provides none of the newly designated services, you will not need to enrol. However, we recommend confirming your position with a qualified AML/CTF adviser.
What is the penalty for not enrolling in time?
Failure to enrol when required is a breach of the AML/CTF Act and can result in civil penalties. AUSTRAC also has powers to conduct compliance assessments and take enforcement action.
When should accounting firms start preparing?
Immediately. Developing a compliant AML/CTF program, conducting a risk assessment, and implementing CDD procedures takes time. Firms that delay may find themselves unable to meet the 29 July 2026 enrolment deadline with a properly functioning compliance framework in place.
Will sole-practitioner accountants be captured?
Potentially yes, if they provide the new designated services. The Act does not exempt businesses based on their size — a sole practitioner providing trust and company services is captured in the same way as a large accounting firm.
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