Accounting Sector
Accounting practices providing designated services are captured under Tranche 2. Here's what you need to know before 1 July 2026.
From 1 July 2026, new AML/CTF compliance obligations (called Tranche 2) will apply to the Accounting Sector. AUSTRAC enrolment opens 31 March 2026.
The path to 1 July 2026 is defined by clear legislative and regulatory milestones
AML/CTF Amendment Act Passed
Nov 2024
Finalisation of AML/CTF Rules
Aug 2025
Core Guidance from AUSTRAC
Oct 2025
Sector-Specific Guidance for Accountants
Jan 2026
AUSTRAC Enrolment Opens
31 Mar 2026
Mandatory Compliance Commences
1 Jul 2026
AUSTRAC's national risk assessment identifies accounting services as high-risk, making them a focus of the reforms. Your preparation starts now.
These reforms are driven by
FATF Standards
The primary driver is the Financial Action Task Force (FATF), the global standard-setter for combating financial crime. Australia is a founding member and subject to its peer reviews.
2015 Evaluation Gap
Australia's 2015 FATF evaluation highlighted a key deficiency: the lack of regulation for "gatekeeper" professions like lawyers, accountants and real estate agents.
Criminal Exploitation
Criminals exploit these professional services to conceal illicit funds, hide beneficial ownership through complex structures and add a veneer of legality to the proceeds of crime.
Tranche 2 Reforms
The Tranche 2 reforms close this long-standing vulnerability, strengthening the integrity of Australia's financial system.
ML/TF/PF Risks in the Accounting Sector
The accounting sector faces unique money laundering (ML), terrorism financing (TF) and proliferation financing (PF) risks. If an entity offers designated services, they will need to be aware of and assess the risks in relation to their business and services offered.
Fraudulent Financials
Manipulated statements
Preparation of misleading financial statements to support loan applications or investment fraud.
Invoice Layering
Trade-based laundering
Complex invoice arrangements designed to move money through legitimate-appearing business transactions.
Third-Party Instructions
Unusual payment requests
Clients requesting payments be made to or received from unexpected third parties.
High-Risk Jurisdictions
Cross-border transactions
Funds flowing through jurisdictions with weak AML controls or known for financial crime.
You are in scope if you provide a 'designated service'
Service-Based Trigger
The regime applies based on the services you provide, not your professional title or whether the work is pro bono.
Wide Professional Capture
This captures partners and directors, outsourced or virtual CFOs, registered Tax and BAS agents, trust and company service providers and bookkeepers.
Service Mapping Required
The first critical step is to conduct a detailed mapping of your service offerings against the nine designated services to determine your regulatory status.
The Nine Designated Services at a Glance
Accountants providing any of these services become reporting entities under the AML/CTF Act.
Real property transactions
Assisting in the sale, purchase, or transfer of real estate.
Sale/transfer of companies
Assisting in the sale, purchase, or transfer of a company or legal arrangement.
Managing client property
Holding, controlling, or managing client money, accounts, or assets for a transaction.
Equity or debt financing
Assisting in organising or executing financing transactions.
Creating or restructuring companies
Assisting in the creation or restructure of companies or legal arrangements (e.g., trusts, new entities).
Selling shelf companies
Selling pre-formed companies or 'shelf' entities to clients.
Providing a director/secretary
Acting as (or arranging for someone to act as) a director, secretary, or partner.
Providing a registered office
Providing a registered office or principal place of business address.
Providing nominee shareholders
Providing nominee shareholders for companies.
When Normal Work Crosses the Line:
- • A bookkeeper who establishes entities for a client or acts as a nominee director.
- • A tax agent who designs and executes a group restructure, not just advises on it.
- • A virtual CFO who negotiates a business sale and manages client funds for the deal.
Who May Be Captured?
The key trigger is designated services. If you are unsure whether you are covered, please take advice. Even if you are not covered, you may consider implementing guardrails.
All firm sizes
From sole practitioners to large practices
Registered tax agents
Providing designated services beyond standard tax work
Corporate service arms
Company formation and ASIC agency services
External CFOs
Outsourced financial management services
Trust service providers
Establishment and administration of trusts
Whether you are captured depends on the designated services you provide. If unsure whether you're covered, please seek legal advice. Even if you are not covered, you may consider implementing guardrails to ensure you don't accidentally cross lines.
Many traditional accounting services remain outside scope
The following activities are generally not designated services, provided they are not part of a broader in-scope service:
Standard Tax Compliance
Preparing and lodging tax returns, BAS and IAS where no designated service is involved.
Standalone Advisory Work
Providing general accounting, tax or financial advice that is not connected to progressing a designated service. Note: if advice assists or is part of a designated service transaction, obligations may still apply.
Audit and Assurance
Conducting audits, reviews and assurance engagements in accordance with professional standards.
Bookkeeping Services
Day-to-day bookkeeping and financial record maintenance, provided the accountant is not also establishing entities or acting in nominee roles.
Superannuation Advice
Advising on superannuation contributions and strategies without managing or controlling client funds.
Financial Reporting
Preparing financial statements and management reports without involvement in underlying transactions.
Once you are a reporting entity, you have six fundamental compliance obligations
1. Enrol with AUSTRAC
Formally register your practice as a reporting entity.
2. Develop & Maintain an AML/CTF Program
Create a written, risk-based program tailored to your firm's specific ML/TF risks. This is the cornerstone of your compliance.
3. Conduct Customer Due Diligence (CDD)
Identify and verify your clients and their beneficial owners before providing a designated service, and monitor them on an ongoing basis.
4. Report to AUSTRAC
Submit Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs) as required.
5. Keep Records
Maintain all relevant records of CDD, transactions and your AML/CTF program for prescribed periods.
6. Appoint an AML/CTF Compliance Officer
Designate a senior individual responsible for the oversight of your program.
Key AML/CTF Areas for Accounting Professionals
Under Tranche 2, accounting professionals face new obligations when providing designated services. Our documentation helps you navigate these requirements with confidence, covering all critical compliance areas specific to accounting service delivery.
Company Formation & Restructuring
Procedures for AML/CTF compliance when forming companies, trusts or restructuring entities for clients.
Trust Administration
AML/CTF controls for trust establishment and ongoing administration, including trustee services.
Client Identity Verification
Initial and ongoing customer due diligence (CDD), including electronic verification methods and document requirements.
Registered Office Services
Compliance requirements when providing registered office or principal place of business addresses.
Beneficial Ownership Records
Requirements for identifying and verifying beneficial owners of entities you service.
Suspicious Matter Reporting
Workflows for identifying, escalating and reporting suspicious matters to AUSTRAC.
Compliance Officer Duties
Appointment requirements, role description and ongoing responsibilities for AML/CTF compliance.
Building an AML Program
Building an AML/CTF program for an accounting practice requires multiple steps.
- AML/CTF program framework for accounting practices
- Risk assessment worksheet (ML/TF/PF risks)
- Client identification and verification procedures
- Company formation compliance workflows
- Trust establishment and administration controls
- Suspicious matter reporting procedures
- Staff Training Register for tracking completion
- Compliance officer role description
Ready to Get Started?
We can help you get a headstart on your AML/CTF program. Sector-specific program documents, no subscription. Portal included (subject to licence terms).
A HeadStart on Compliance
Sector-specific compliance documents to help you build your AML/CTF program.
Ready-to-Customise Resources
Lawyer-ready to review for your business.
Training & Record-Keeping
Staff Training Register, Compliance Officer appointment documents and portal-based training record-keeping.
From $249 inc GST · or bring your own program
HeadStart Docs™ products are developed with reference to publicly available regulatory guidance. This is general information only and does not constitute legal or professional advice. You should seek advice specific to your circumstances before making compliance decisions.