AML/CTF Program Development
Create written policies and procedures tailored to your practice size, client base, and designated services offered.
Accountants | Compliance
AML Compliance for Accountants
Complete AML/CTF compliance guide for accountants. Learn about designated services, customer due diligence, suspicious matter reporting, and building your AML/CTF program.
Key Information
Building Your AML/CTF Compliance Program
AML compliance for accountants requires a risk-based approach tailored to your practice. From 1 July 2026, accountants providing designated services must enrol with AUSTRAC and meet comprehensive AML/CTF obligations.
AUSTRAC identifies accountants as high-risk gatekeepers whose services can be misused to establish structures, manage finances, and provide legitimacy for criminal operations. Your compliance program must address these risks through customer due diligence, ongoing monitoring, and suspicious matter reporting.
Building Your AML/CTF Program
Customer Due Diligence
Verify client identity, identify beneficial owners, understand business purpose, and determine PEP/sanctions status.
Risk Assessment
Assess ML/TF risks for your practice, client types, services, and delivery channels. Document and review annually.
Suspicious Matter Reporting
Report to AUSTRAC when you suspect ML/TF activity—within 24 hours for terrorism, 3 days for other suspicions.
Record Keeping
Maintain customer identification, transaction records, and compliance documentation for 7 years minimum.
Staff Training
Train all staff on AML/CTF obligations, red flags, and your firm's procedures. Document training records.
Frequently asked questions
What services require AML compliance for accountants?
Designated services include: forming companies/trusts, managing client money or property, providing registered office addresses, acting as nominee directors/secretaries, trust administration, and assisting with corporate transactions. Standard accounting, tax and audit services are NOT designated services.
Do small accounting practices need to comply?
Yes. All accountants providing designated services must comply regardless of business size. AUSTRAC provides guidance and starter kits for smaller practices. The scope of your AML/CTF program should be proportionate to your practice.
What is required for Customer Due Diligence?
Before providing designated services you must: verify customer identity using reliable documents, identify beneficial owners for company/trust clients, determine if customers are PEPs, understand the purpose of the business relationship, and apply enhanced due diligence for high-risk customers.
How do I report suspicious matters?
Submit Suspicious Matter Reports (SMRs) to AUSTRAC via AUSTRAC Online. Report within 24 hours if terrorism financing is suspected, or within 3 business days for other suspicions. Tipping off clients about SMRs is prohibited.
What records must accountants keep?
Retain for 7 years: customer identification documents, records of designated services provided, transaction records, your AML/CTF program documentation, staff training records, and any correspondence with AUSTRAC.
Streamline Your AML Compliance
ARCaml automates customer due diligence and ongoing monitoring for accounting practices.