AUSTRAC Enrolment
Register as a reporting entity via the AUSTRAC Business Profiles Portal. Enrolment opens 31 March 2026, with deadline 29 July 2026. You'll need ABN, business details, and designated service information.
AUSTRAC Requirements
AUSTRAC AML Obligations for Accountants
Complete guide to AUSTRAC AML/CTF obligations for accountants under Tranche 2 reforms. Learn about designated services, customer due diligence, and reporting requirements starting 1 July 2026.
Key Information
Understanding Your AUSTRAC Obligations as an Accountant
From 1 July 2026, accountants providing certain services become reporting entities under Australia's Anti-Money Laundering and Counter-Terrorism Financing Act. This means you must comply with AUSTRAC's regulatory framework when providing designated services.
Why AUSTRAC Regulates Accountants
AUSTRAC has identified accountants as high-risk gatekeepers in the financial system. The FATF (Financial Action Task Force) and AUSTRAC recognise that accountants can be misused to:
- Create corporate structures that obscure beneficial ownership
- Move and manage illicit funds through client trust accounts
- Provide legitimacy to transactions through professional involvement
- Assist with complex arrangements that disguise the source of funds
Your AUSTRAC Obligations
When you provide designated services, you must:
- Enrol with AUSTRAC via the Business Profiles Portal (opens 31 March 2026)
- Develop an AML/CTF program that includes:
- Part A: Customer identification and verification procedures
- Part B: ML/TF risk assessment and management
- Conduct Customer Due Diligence (CDD) before providing designated services
- Report suspicious matters to AUSTRAC within required timeframes
- Keep records for at least 7 years
- Provide training to staff on AML/CTF obligations
Key Timeline
- 31 March 2026: AUSTRAC enrolment opens
- 1 July 2026: AML/CTF obligations commence
- 29 July 2026: Deadline to complete AUSTRAC enrolment
Penalties for Non-Compliance
AUSTRAC has significant enforcement powers. Penalties for non-compliance include:
- Civil penalties up to $28.2 million for corporations
- Civil penalties up to $5.64 million for individuals
- Infringement notices and enforceable undertakings
- Criminal prosecution for serious breaches
- Remedial directions requiring specific compliance actions
Key Requirements
ML/TF Risk Assessment
Assess the money laundering and terrorism financing risks specific to your accounting practice. Consider client types, services offered, geographic exposure, and delivery channels.
AML/CTF Program Development
Create a written AML/CTF program with Part A (customer identification procedures) and Part B (ML/TF risk assessment). The program must be tailored to your practice's risk profile.
Customer Due Diligence
Identify and verify clients before providing designated services. Collect full name, DOB, residential address. Verify against government documents or trusted electronic sources.
Suspicious Matter Reports
Report to AUSTRAC within 24 hours (terrorism) or 3 business days (other suspicions) when you suspect ML/TF activity. Reports are confidential and protected by law.
Record Keeping
Retain CDD records, transaction records, and AML/CTF program documentation for 7 years. Records must be retrievable and available for AUSTRAC examination.
Frequently asked questions
What accounting services trigger AUSTRAC obligations?
You have AML/CTF obligations when providing designated services: (1) Managing client money, securities or property including trust accounts, (2) Creating, operating or managing companies, trusts or partnerships, (3) Arranging contributions to companies or trusts, (4) Buying/selling businesses or legal entities, and (5) Acting as registered agent, director or secretary. Standard tax returns, bookkeeping, and financial statement preparation are NOT designated services.
How do I enrol with AUSTRAC?
Use the AUSTRAC Business Profiles Portal from 31 March 2026. You'll need your ABN, business contact details, nature of designated services, estimated transaction volumes, and compliance officer details. Complete enrolment by 29 July 2026. If you already have AUSTRAC enrolment for other services (e.g., registered tax agent), you'll need to update your profile.
What happens if I don't comply with AUSTRAC requirements?
Non-compliance can result in significant civil penalties (up to $28.2 million for corporations), infringement notices, enforceable undertakings, and in serious cases, criminal prosecution. AUSTRAC has broad examination powers and can require document production and attendance at examinations. Your professional registration may also be at risk.
Do I need an AML/CTF compliance officer?
Yes. Your AML/CTF program must designate a compliance officer responsible for program oversight, reporting to senior management, ensuring staff training, monitoring effectiveness, and updating procedures. In small practices, this may be a principal, but they must have adequate authority and resources.
Meet Your AUSTRAC Obligations
ARCaml provides comprehensive AML/CTF compliance tools designed for accounting practices. Automate customer verification, manage ongoing due diligence, and generate AUSTRAC reports before obligations commence 1 July 2026.