Designated Services
Managing client money, company formation, financial advice, and tax services trigger AML obligations.
Accountants
Accounting Compliance
AML compliance requirements for accountants and accounting firms in Australia. From July 2026, accountants become AUSTRAC reporting entities under Tranche 2 reforms.
Key Information
AML Compliance for Accounting Firms
Accounting compliance is changing in Australia. From 1 July 2026, accountants and accounting firms providing designated services become reporting entities under the AML/CTF Act Tranche 2 reforms. This means new obligations including customer due diligence, suspicious matter reporting, and maintaining an AML/CTF program.
The reforms recognize that accountants can be targeted by criminals seeking to launder money through legitimate business structures. Understanding your obligations now gives you time to prepare systems, train staff, and implement compliant processes before the deadline.
Accounting AML Obligations
Client Due Diligence
Verify client identity, beneficial ownership, and assess money laundering risk before engagement.
AML/CTF Program
Develop documented policies and procedures tailored to your accounting practice.
Suspicious Matter Reporting
Report suspicious matters to AUSTRAC when you suspect ML/TF.
Record Keeping
Maintain client identification and transaction records for 7 years.
Staff Training
Train staff on AML obligations, red flags, and reporting procedures.
Frequently asked questions
When do AML obligations apply to accountants?
From 1 July 2026, accountants providing designated services become reporting entities under the AML/CTF Act Tranche 2 reforms. This includes managing client money, company formation assistance, and certain financial advice services.
What services trigger AML obligations for accountants?
Designated services include: managing client money or securities, assisting with company/trust formation, acting as nominee director/shareholder, providing registered office services, and preparing or reviewing financial statements when combined with other designated services.
Do all accounting firms need to comply?
Only accounting firms providing designated services with a geographical link to Australia need to comply. Routine tax preparation and bookkeeping alone don't trigger AML obligations, but combined services may.
What is the penalty for non-compliance?
AUSTRAC can impose significant civil penalties (potentially millions of dollars), enforceable undertakings, and in serious cases, criminal prosecution. Reputational damage can also be severe.
AML Compliance for Accountants
ARCaml helps accounting firms meet their new AML/CTF obligations with outsourced CDD services.