AML Obligations for Accountants

From 1 July 2026, a lot of accounting practices that have never given money laundering a second thought become reporting entities under the AML/CTF Act. I run a tax and accounting practice in Sydney, and I am the appointed AML/CTF Compliance Officer for ours, so I have spent the past year reading the reforms closely. The most useful thing I can pass to another accountant is one line AUSTRAC keeps repeating: it is what you do, not what you are.

The regime does not regulate accountants. It regulates a list of services. You can run a busy firm with hundreds of clients, do tax returns and BAS all day, and sit completely outside the net. Provide one service on the list, even once, even for no fee, and you are in.

So the question is narrow, and you can actually answer it: do you provide a designated service?

What actually triggers it

The new services for our profession live in Table 6 of section 6 of the Act. There are 9 of them. They are written around companies, trusts and property, because that is where the laundering risk concentrates. The full list of designated services is profession-neutral, so it helps to read it through what a practice actually does.

These are the ones I see ordinary practices hit. Setting up a company or a trust for a client. Restructuring one. Acting as a trustee, a director or a secretary, or arranging for someone else to. Putting your firm’s address down as the registered office. Holding a client’s money to help a transaction go through. Helping someone buy or sell a business. Most accountants do at least one of these without thinking of it as anything special.

Look at what is not there. Preparing a tax return. Lodging a BAS. Bookkeeping. Audit and assurance. General tax advice. On their own, none of those is a designated service, and that single fact decides whether the whole regime lands on your desk.

Item	The designated service	What it looks like in practice
1	Transferring real estate	Helping a client buy, sell or transfer property as part of a transaction
2	Buying or selling a company or trust	Assisting a client to buy, sell or transfer a body corporate or legal arrangement
3	Holding client money for a deal	Receiving, holding or managing a client’s money or property to move a transaction along
4	Equity or debt financing	Helping organise financing for a company or trust
5	Selling a shelf company	Selling a ready made company that has never traded
6	Creating or restructuring a structure	Setting up or restructuring a company or trust
7	Director, trustee or secretary	Taking, or arranging someone to take, a fiduciary role in a structure
8	Nominee shareholder	Acting as, or arranging, a nominee shareholder
9	Registered office address	Providing your firm address as the registered office or principal place of business

From my desk. A long-standing client wants to buy an investment property through a structure, so we set up a discretionary trust with a corporate trustee, and the client asks us to be the registered office. Routine. We have done that exact setup a hundred times. The point that took me a while to sit with is that this one engagement touches three Table 6 items at once: creating the structure (item 6), acting as or arranging the trustee and director (item 7), and providing the registered office (item 9). The work that feels most ordinary is the work the reforms are built around. That is the part worth slowing down on.

Once a service puts you in

The obligations are the same ones every reporting entity carries, scaled to the size and risk of your practice.

You enrol with AUSTRAC. Enrolment opened on 31 March 2026, and if you are providing a designated service on 1 July 2026 you have until 29 July 2026 to get it done. The step by step on enrolling walks through the AUSTRAC Online side of it.

You appoint an AML/CTF compliance officer at management level. In a sole practice or a small firm, that is usually the principal.

You build and maintain an AML/CTF program. Under the reformed Act it has two components: a documented ML/TF risk assessment, and AML/CTF policies that answer what the assessment found. The old Part A and Part B split is gone. Nobody hands you a prescribed shape to fill in any more, which sounds easier and is not.

You do customer due diligence before you provide the service, not after the deal is done. And you report and keep records: suspicious matter reports, threshold transaction reports where they apply, and a trail that holds up later.

What is carved out

There is real relief built in, and it matters, because without it half the profession would be caught on technicalities.

Handling client money for routine, ancillary payments does not pull you in on its own. Paying a client’s ATO tax bill, ASIC fees, court filing fees, an insurance premium, that incidental movement of funds is carved out. The exclusion exists so ordinary, low-risk handling of client money is not treated as a designated service.

In-house work is generally outside it too. An internal finance or legal team serving its own employer is not separately a reporting entity, though the employer might be. And backward-looking work tends to be safe: advising on whether a transaction that already happened was valid is not the same as helping one happen. Table 6 is about matters in progress or ahead of you, not history.

The trap inside all of that: one-off counts, low-volume counts, and free counts. The exemptions turn on the type of activity, not how often or how cheaply you do it.

The exercise to run before July

Take your actual service menu, the real one, including the things you do once a year as a favour, and lay it next to Table 6. For each service, trace it to what happens in the world. Does money move? Does an entity get created? Does ownership change hands? If the honest answer is yes, you are probably looking at a designated service, and you plan accordingly. AUSTRAC’s own tool and the program starter kits are a reasonable place to pressure-test your read.

The legal question, are you caught, is answerable in an afternoon. The operational one lingers: proving, later, that you did customer due diligence before you acted, with the evidence locked to its source and ready for an audit. That is the part most firms underestimate, and it is the problem HP-KYC was built to take off your desk. Document, officer check, then locked to source, so the trail is there when someone asks for it.

For the wider picture of what the reforms mean for a small firm, start with what Tranche 2 means for your firm.

The legal detail

Legislative references and dates, current as at June 2026. General information, not advice for a specific practice.

• Designated services for professionals: Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) s 6, Table 6 (Professional services), inserted as subsection 6(5B) by Schedule 3, Part 3 of the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) (C2024A00110). Table 6 commences 1 July 2026.
• Table 6 items: (1) assisting to sell, buy or transfer real estate; (2) assisting to sell, buy or transfer a body corporate or legal arrangement; (3) receiving, holding, controlling or managing a person’s money or property to assist a transaction; (4) equity or debt financing for a body corporate or legal arrangement; (5) selling a shelf company; (6) creating or restructuring a body corporate or legal arrangement; (7) acting as, or arranging for a person to act as, a director, secretary, trustee, partner or similar fiduciary role; (8) acting as, or arranging for a person to act as, a nominee shareholder; (9) providing a registered office or principal place of business address.
• Geographical link: s 6(6). An item applies only where the service is provided at or through a permanent establishment in Australia.
• Incidental client-money exclusions: s 6(5C) to (5E). The AML/CTF Rules carve item 3 out for routine ancillary payments, including tax payments to the ATO, ASIC filing fees, court filing fees, insurance payments, and bail paid through a trust account.
• Commencement and enrolment: enrolment opens 31 March 2026; obligations commence 1 July 2026; an entity providing a designated service on 1 July 2026 must enrol by 29 July 2026.
• AML/CTF program: section 26B, Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). Two components: an ML/TF risk assessment (sections 26C to 26E) and AML/CTF policies (section 26F). The prescribed Part A and Part B structure was removed by the reforms. Independent evaluation: your AML/CTF policies set the frequency, and it must be at least once every 3 years. The Anti-Money Laundering and Counter-Terrorism Financing Transitional Rules 2026 stagger the deadline for a newly regulated entity’s first evaluation.
• Scale: AUSTRAC and industry estimates put the newly regulated population at roughly 80,000 to 90,000 businesses, taking the regime to around 100,000 reporting entities.
• Source framing: AUSTRAC professional services reform guidance, October 2025: the regime regulates services, not professions, so it is what you do, not what you are.