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Australia is undergoing one of the most significant regulatory shifts in decades with the expansion of its Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime. From 1 July 2026, accounting firms providing certain services will be brought into the AML/CTF framework under the so-called “Tranche 2” reforms.
These changes aim to align Australia with global standards and close long-standing gaps that allowed professional service providers - such as accountants, lawyers, conveyancers, trust and company service providers - to potentially be unwittingly used in facilitating financial crime or, far worse still, intentionally facilitate it.
Historically, Australia’s AML/CTF laws applied mainly to banks, financial institutions and gambling providers. However, global bodies such as the Financial Action Task Force (FATF) have pushed for broader coverage of “designated non-financial businesses and professions,” including accountants.
Accountants are considered high-risk intermediaries because they often:
- Structure companies and trusts
- Manage client funds
- Facilitate transactions or asset transfers
These services can be exploited to disguise illicit funds or conceal beneficial ownership.
What’s changing: Key AML rules for accountants
1. Expansion to “Tranche 2 Entities”
From 1 July 2026, accounting firms providing certain “designated services” will be regulated under the AML/CTF Act.
These services include:
- Assisting with buying/selling businesses or real estate
- Creating or restructuring companies and trusts
- Managing client funds, assets or digital assets
- Acting as nominee directors or trustees
- Providing registered office or business addresses
2. Mandatory AUSTRAC registration
Affected firms must:
- Enrol with AUSTRAC (opens 31 March 2026)
- Be registered as a reporting entity
Once your firm enrols with AUSTRAC, you officially become a regulated “reporting entity”. From that point, you are expected to operate under the AML/CTF regime, not just be registered.
AUSTRAC requires periodic reporting on your compliance.
- Typically an annual compliance report.
- This report would cover your AML program, risks assessment, controls and governance, and how you are meeting you AML/CTF obligations.
- Additionally, notify AUSTRAC of changes (within ~14 days) & update business details, services, or structure.
Think of this as AUSTRAC checking: “Are you actually doing what you said you would?”
Once enrolled, AUSTRAC can:
- Request information
- Conduct audits or reviews
- Enforce penalties for non-compliance
This is the biggest mindset shift: You are now a regulated entity under active supervision and should actively detect, assess, and report financial crime risks on an ongoing basis.
3. AML/CTF Compliance Program
Firms must implement a risk-based AML/CTF program that:
- Identifies money laundering risks
- Sets internal controls and procedures
- Establishes governance and oversight structures
Crucially: you are expected to have this operational, not just drafted.
4. Customer Due Diligence (CDD / KYC)
Accounting firms will need to:
- Verify client identity
- Understand beneficial ownership
- Assess risk levels of clients and transactions
This applies both to new clients and, in some cases, existing ones.
5. Ongoing monitoring & reporting
Firms must:
- Monitor transactions for suspicious activity
- Report suspicious matters to AUSTRAC
- Maintain detailed records of client interactions and checks
Key reporting obligations include:
Suspicious Matter Reports (SMRs)
- Report any suspicious client or transaction
- No minimum dollar threshold
- Strict deadlines (as little as 24 hours in some cases)
Threshold Transaction Reports (TTRs)
- Required for cash transactions ≥ $10,000
International Transfer Reports (IFTIs)
- For money sent or received overseas (any value)
This is where accounting firms shift from passive advisors to active gatekeepers of financial crime.
6. Governance and training requirements
Firms are expected to:
- Appoint a compliance officer
- Train staff on AML obligations
- Maintain internal reporting processes & record keeping
Record keeping becomes mandatory. You must keep detailed records of:
- Client identification
- Transactions
- AML decisions and risk ratings
- Your AML/CTF program
These must be:
- Secure
- Accessible
- Retained for regulatory review
Practical impact on accounting firms
Increased compliance burden
Most accounting firms, potentially 80–90% of practitioners, will be affected.
This means:
- More documentation and administrative work
- Changes to onboarding processes
- Increased scrutiny of client relationships
Operational changes
Firms will need to:
- Implement new systems and controls
- Integrate AML checks into workflows
- Possibly adopt compliance technology
Risk and penalties
Failure to comply may result in:
- Regulatory penalties
- Reputational damage
- Increased audit and oversight
Opportunities from the reforms
While burdensome, the reforms also:
- Enhance trust in the profession
- Align Australian firms with global standards
- Reduce exposure to financial crime risks
How firms should prepare
Preparing for AML/CTF obligations is not just a compliance exercise; it requires operational, cultural, and systems changes. Below are practical steps firms can take now to get ready before July 2026.
To get ready:
- Assess whether you provide designated services
- Register early with AUSTRAC
- Develop an AML/CTF program
- Train staff and appoint a compliance officer
- Review client onboarding and risk processes
Practical steps:
1. Map your services against “designated services”
Start by identifying exactly where you are exposed.
Practical tips:
- List all services your firm offers (e.g. tax, advisory, structuring, SMSFs, bookkeeping)
- Highlight services that may fall under AML (e.g. company formation, trust structuring, handling client funds)
- Break this down by team or department, not just firm-wide
Many firms underestimate exposure because AML obligations apply to specific activities, not the whole firm.
2. Conduct a simple risk assessment first (don’t overcomplicate it)
Before building a full AML program, do a high-level risk scan.
Focus on:
• Client types (e.g. high-net-worth, overseas clients, complex structures)
• Industries (cash-heavy businesses, crypto, real estate)
• Geographic risk (clients with offshore links)
Practical tip:
Start with a traffic light system:
🔴 High risk
🟡 Medium risk
🟢 Low risk
This becomes the foundation of your AML program later.
3. Redesign client onboarding (the biggest change)
AML compliance will fundamentally change how you onboard clients.
What to implement:
- Identity verification (ID checks, company searches)
- Beneficial ownership checks (who actually controls the entity)
- Risk rating at onboarding
Practical tips:
- Add AML steps into your existing onboarding checklist, don’t create a separate process
- Use standardised forms/templates for consistency
- Consider digital ID verification tools to reduce admin burden
If onboarding isn’t fixed early, compliance becomes messy later.
4. Build a “minimum viable” AML/CTF program first
Don’t aim for perfection, start with a workable version.
Core components:
- Risk assessment document
- Policies & procedures (how you handle AML)
- Client due diligence process
- Reporting process (who escalates suspicious matters)
Practical tips:
- Use templates (from industry bodies like CPA/CAANZ if available)
- Keep language simple, staff actually need to understand it
- Assign one owner internally (don’t let it sit “everywhere”)
5. Appoint an AML champion (even before a formal compliance officer)
You don’t need a full compliance team yet, but you do need ownership.
Practical tips:
- Choose someone senior enough to influence processes
- Ideally from operations, not just technical accounting
- Give them time and authority (this can’t be a “side task”)
6. Train staff early (focus on awareness first)
Most AML failures come from people, not systems.
Start with:
- What AML is and why it matters
- Red flags (unusual transactions, secrecy, complex structures)
- What to do if something feels “off”
Practical tip:
Use real-world scenarios, e.g.:
- “Client wants to set up multiple entities with no clear purpose”
- “Client reluctant to provide ID”
Staff don’t need legal detail, they need practical judgment.
7. Introduce ongoing monitoring (keep it simple)
You’re not expected to monitor everything, but you must be alert to changes.
Practical approach:
- Flag high-risk clients for periodic review (e.g. annually)
- Add a checkpoint when:
o Services change
o Transactions become unusual
o New entities are introduced
8. Document everything (if it’s not documented, it didn’t happen)
Regulators care heavily about evidence of compliance.
What to document:
- Client ID checks
- Risk assessments
- Decisions (e.g. why a client is low/high risk)
- Internal escalations
Practical tip:
Use your existing practice management system where possible, don’t create scattered records.
9. Leverage technology (but don’t overinvest too early)
There will be a surge in AML software but not all firms need complex tools immediately.
Start with:
- Digital ID verification tools
- Basic workflow/checklist tools
- Secure document storage
Upgrade later if:
- You have high client volume
- You deal with complex/high-risk clients
10. Engage external support strategically
You don’t have to do everything in-house.
Consider:
- AML consultants (for program setup)
- Legal advice (for grey areas)
- Industry guidance (CPA, CAANZ, IPA resources)
Practical tip:
Use external help to set up the framework, then manage internally.
11. Run a “dry test” before July 2026
Before the rules go live, simulate compliance.
Example:
- Take 5–10 existing clients
- Run them through your new AML process
- Identify gaps or friction
This is one of the most effective ways to find real issues early.
Practical impact on the clients of accounting firms
The expansion of Australia’s AML/CTF regime to accounting firms will not only transform how firms operate, it will also have a direct and noticeable impact on their clients. From onboarding to ongoing engagements, clients will experience increased scrutiny, new information requirements, and changes in how services are delivered.
1. More documentation and identity checks
Clients will be required to provide more detailed personal and business information than before.
This includes:
• Proof of identity (e.g. passport, driver’s licence)
• Verification of company ownership structures
• Disclosure of beneficial owners
For some clients, particularly those with complex structures, this may feel intrusive or repetitive.
Impact: Longer onboarding times and increased administrative effort for clients.
2. Greater transparency expectations
Clients will need to be more transparent about:
• Source of funds and wealth
• Purpose of transactions
• Business activities and structures
Accountants may ask more probing questions, especially where transactions appear unusual or high-risk.
Impact: Clients may need to justify decisions that were previously taken at face value.
3. Delays in service delivery
With additional compliance steps built into workflows, clients may experience:
• Slower onboarding
• Delays in executing transactions or setting up entities
• Additional review steps before advice is provided
Impact: Time-sensitive transactions may require earlier planning and coordination.
4. Increased costs
Compliance obligations will increase operational costs for accounting firms, which may be passed on to clients through:
• Higher fees
• Separate compliance or onboarding charges
Impact: Clients may see a rise in the cost of professional services.
5. Ongoing monitoring and follow-ups
Clients will no longer be assessed only at onboarding, firms will conduct ongoing monitoring.
This means clients may:
• Be asked to update their information periodically
• Receive queries about transactions or changes in structure
• Undergo re-verification if risk profiles change
Impact: The client-accountant relationship becomes more continuous and compliance-driven.
6. Reduced anonymity in financial structures
AML rules focus heavily on identifying beneficial ownership, reducing the ability to use opaque structures.
Clients using the following, will face increased scrutiny:
• Trusts
• Layered entities
• Offshore arrangements
Impact: Less flexibility for clients seeking privacy in structuring (legitimate or otherwise).
7. Potential refusal or termination of services
Accounting firms will be required to decline or disengage from high-risk clients where risks cannot be managed.
This may occur if:
• Clients refuse to provide required information
• Activities appear suspicious
• Risk levels exceed firm tolerance
Impact: Some clients may find it harder to access accounting or advisory services.
8. Shift in client experience and expectations
Overall, clients will notice a shift from a purely advisory relationship to one that includes regulatory oversight responsibilities.
Accountants will act not only as advisors, but also as:
• Gatekeepers of financial integrity
• Obligated reporters to AUSTRAC
Impact: Clients may need to adjust expectations around confidentiality and responsiveness.
Key takeaway
Firms that succeed will treat AML not as a regulatory burden, but as a process redesign exercise. The goal is to embed compliance into everyday workflows, especially onboarding, rather than layering it on top.
The AML/CTF Tranche 2 reforms represent a major shift for the accounting profession in Australia. By extending regulatory oversight to accounting firms, the government aims to strengthen financial integrity and combat illicit activities more effectively.
For accounting firms, early preparation will be critical, not only to ensure compliance but to integrate these obligations efficiently into business operations.
Enrolment with AUSTRAC is not a one-off administrative step, it marks the point at which accounting firms enter an ongoing regulatory regime involving continuous monitoring, reporting, and compliance obligations.
For clients, the key to navigating this new environment will be preparedness, transparency, and early engagement with their advisors.
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