AML/CTF Tranche 2: a guide for Australian accounting firms

From 1 July 2026, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (the Act) applies to accountants who provide certain services. AUSTRAC calls these businesses tranche 2 reporting entities. The obligations are the same family of obligations banks have lived with for years: enrol, run an AML/CTF program, know your customer, report suspicious matters and keep records. What is new is that they now attach to a defined list of professional services, not to the whole of your practice.

This guide sets out what the law says, where it says it, and how it plays out on the kinds of family group work most Australian firms do every week. Every rule is cited to AUSTRAC guidance, the Act as amended by the AML/CTF Amendment Act 2024, or the AML/CTF Rules 2025.

The short version

• Obligations started on 1 July 2026 for tranche 2 entities, including accountants (AUSTRAC factsheet).
• You must enrol with AUSTRAC within 28 days of first providing a designated service. For services provided from 1 July 2026, AUSTRAC gives that date as 29 July 2026.
• Only the services in table 6 of section 6 of the Act are designated services. Most are about transactions and structures: buying and selling real estate or businesses, setting up companies and trusts, acting as director, secretary or trustee, holding client money, and providing a registered office.
• Before you provide a designated service, you must complete initial customer due diligence (section 28). After that, ongoing due diligence applies for the life of the relationship (section 30).
• Suspicious matter reports are due within 24 hours for terrorism financing and within 3 business days otherwise. Threshold transaction reports apply to physical currency of A$10,000 or more.
• Most records must be kept for 7 years.

Key dates

Date or timeframe	What happens	Source
1 July 2026	AML/CTF obligations apply to tranche 2 entities, including accountants	AUSTRAC factsheet; AUSTRAC, Check if you may be regulated
Within 28 days of first providing a designated service	Enrol with AUSTRAC. AUSTRAC states this is typically 29 July 2026 for new services	AUSTRAC factsheet
Within 28 days of first providing a designated service	Designate an AML/CTF compliance officer, if none is designated	Act s 26K(1)
Within 14 days of designating a compliance officer	Notify AUSTRAC of the compliance officer. For a newly regulated business, the transitional rules set the first notification at the later of 14 days after enrolment or 29 July 2026 (AUSTRAC example: enrolled 29 July 2026, notify by 12 August 2026)	Act s 26M; AUSTRAC, AML/CTF transitional rules 2026
Within 14 days of a change	Update your enrolment details	AUSTRAC factsheet
At least once every three years	Independent evaluation of your AML/CTF program (and in certain other circumstances)	AUSTRAC factsheet
30 June 2029 to 31 December 2030	First independent evaluation for a newly regulated business. The date depends on the last two digits of the AUSTRAC account number (AAN): both odd, 30 June 2029; second-last odd and last even, 31 December 2029; both even, 30 June 2030; second-last even and last odd, 31 December 2030	AUSTRAC, AML/CTF transitional rules 2026

Which accountant services are designated services

The professional designated services sit in table 6, subsection 6(5B) of the Act. AUSTRAC describes the nine items as follows. They apply when the service is provided in the course of carrying on a business.

Table 6 item	Designated service (AUSTRAC's wording)	Typical accounting firm example
1	Assisting a person in the planning or execution of a transaction to sell, buy or transfer real estate	Acting on a client's purchase of a commercial property once you are instructed and directly advancing the deal
2	Assisting a person in the planning or execution of a transaction to sell, buy or transfer a body corporate or legal arrangement (a controlling interest)	Acting on the sale of a client's company once there is one buyer and you are instructed to act
3	Receiving, holding and controlling (including disbursing) or managing a person's money, accounts, securities, virtual assets or other property, as part of assisting in a transaction	Holding settlement funds in the firm's trust account for a client's transaction
4	Assisting a person in organising, planning or executing a transaction for equity or debt financing of a body corporate or legal arrangement	Running a capital raise or arranging debt for a client company
5	Selling or transferring a shelf company	Selling a client a ready-made company
6	Assisting a person to plan or execute, or otherwise acting on behalf of a person in, the creation or restructuring of a body corporate or legal arrangement	Registering a new company with ASIC, drafting and settling a family trust or SMSF deed
7	Acting as, or arranging for another person to act as, a director or secretary of a company, power of attorney, partner, express trustee, or equivalent position	A partner acting as company secretary for a client company
8	Acting as, or arranging for another person to act as, a nominee shareholder	Holding shares as nominee for a client
9	Providing a registered office address or principal place of business address	Using the firm's address as a client company's registered office

Source: AUSTRAC, Professional designated services. The examples in the right-hand column are illustrations of the item, not AUSTRAC wording.

Where AUSTRAC draws the line

AUSTRAC's guidance on professional designated services sets out several exclusions and boundaries that matter to accountants:

• Influence is not the same as advancing a transaction. Services that merely influence a customer's choices, general advice and post-transaction advice are generally not covered. AUSTRAC's example: tax advice on selling a company is not covered where it does not directly advance the transaction. Coverage starts once there is clearly one buyer and the accountant is instructed to act, or once negotiations begin with one of several potential buyers.
• Fees held in trust. Money held in trust as payment for the firm's own services is excluded from item 3, as are funds incidental to non-designated services and payments to government bodies, courts and insurers. Using a trust account as a de facto bank account is not excluded.
• Some positions under item 7 are excluded, including powers of attorney for natural persons, trustees of testamentary trusts or trusts not created in writing, and fiduciary roles under a court order.
• Testamentary trusts are outside the Act's definition of an express trust, and AUSTRAC says creating one does not constitute a designated service under items 2 and 4 to 9.
• Internal changes such as staffing or IT systems that do not alter legal form are not a restructure under item 6. Corporations under the Corporations (Aboriginal and Torres Strait Islander) Act 2006 are also excluded from item 6.
• Court or tribunal orders. For items 1 and 2, services carried out after, and pursuant to, an order of a court or tribunal are excluded.

What about tax returns, BAS and financial statements?

Routine compliance work, such as preparing an income tax return, a BAS or annual financial statements, is not among the nine items in table 6. AUSTRAC's guidance pages we reviewed do not address tax return preparation directly, so the safe reading is the narrow one: the obligations attach to the listed services, and a client who only receives compliance work is not receiving a designated service. The same client becomes a customer for AML/CTF purposes the moment you provide them a table 6 service, such as registering a new company or acting on the sale of their business. Check each engagement against the table, service by service.

Enrolment

A firm that provides a designated service must enrol with AUSTRAC within 28 days of first providing it. AUSTRAC states that for services first provided from 1 July 2026, the date is typically 29 July 2026. Changes to enrolment details must be notified within 14 days (AUSTRAC factsheet). If your firm has not yet provided a designated service, the 28 days run from the day you first do.

Your AML/CTF program

Under section 26B of the Act, an AML/CTF program has two parts: your ML/TF risk assessment (section 26C) and the AML/CTF policies that respond to it (section 26F). Governance obligations sit around both. The risk assessment and the policies must each be reviewed at least once every 3 years (sections 26D and 26F).

ML/TF risk assessment

Your money laundering, terrorism financing and proliferation financing risk assessment identifies the risks your business may face in providing designated services (AUSTRAC factsheet). For an accounting firm, the starting questions are the ones the Act uses for customer risk in section 28(4): the kinds of customers you have, the designated services you provide, how you deliver them (in person, remotely, through agents), and the countries you deal with. A suburban practice that sets up a handful of family trusts and companies each year has a very different profile from a firm that routinely holds settlement monies for offshore buyers.

AML/CTF policies

Policies set out how you will manage the risks you identified, including how you carry out customer due diligence, when you apply enhanced or simplified measures, and how staff escalate unusual matters. AUSTRAC states policies must be kept up to date to reflect significant changes to your business and its risks. If you intend to use simplified due diligence, Rule 6-16 requires your policies to deal with how you apply it.

Governance and senior managers

AUSTRAC's senior managers quick guide says your business must nominate one or more senior managers to make important AML/CTF decisions, and those senior managers cannot delegate their obligations. Senior managers approve:

• the AML/CTF program, including updates to its policies
• the ML/TF risk assessment and updates to it
• any arrangement to use a third party to collect and verify CDD information
• starting to provide designated services to certain politically exposed persons, including foreign PEPs and some high-risk domestic or international organisation PEPs
• starting or continuing a customer relationship in the circumstances your policies set out

The governing body must oversee the program, and the business must keep records showing senior managers met their obligations. Internal reviews and independent evaluations are required in certain circumstances and at least once every three years (AUSTRAC factsheet; senior managers quick guide).

The AML/CTF compliance officer

Section 26J of the Act requires every reporting entity to designate an individual as its AML/CTF compliance officer. That person must:

• be employed or otherwise engaged by the firm at management level
• have sufficient authority, independence and access to resources and information to do the job effectively
• be a resident of Australia, if the firm provides its designated services through a permanent establishment in Australia
• be a fit and proper person, having regard to the matters in the Rules (Rule 5-14)

If no one is designated when you start providing a designated service, you have 28 days to designate someone (section 26K). The compliance officer oversees day-to-day compliance and communicates with AUSTRAC (AUSTRAC factsheet). In a small firm this is often a partner or the practice manager, provided they meet the tests above.

The AUSTRAC accountant starter kit

AUSTRAC publishes an accountant program starter kit to help small accountancy firms create an AML/CTF program (AUSTRAC, Accountants). AUSTRAC also lists ML/TF risk indicators for accountants and an ML/TF risk assessment framework quick guide for accountants on the same industry page. The starter kit is the logical place for a small practice to begin, adapted to the services you actually provide.

Customer due diligence

Customer due diligence (CDD) is the part of the regime your clients will notice. The Act now frames it as a set of matters you must establish on reasonable grounds, with the depth of collection and verification scaled to risk.

Initial CDD: what you must establish

Section 28(1) says a reporting entity must not commence to provide a designated service to a customer unless it has established on reasonable grounds each of the following (section 28(2)):

1. the identity of the customer
2. the identity of any person on whose behalf the customer is receiving the service
3. the identity of any person acting on behalf of the customer, and their authority to act
4. if the customer is not an individual, the identity of any beneficial owners
5. whether the customer, any beneficial owner, any person on whose behalf the customer is receiving the service, or anyone acting for the customer is a politically exposed person or a person designated for targeted financial sanctions
6. the nature and purpose of the business relationship or occasional transaction
7. any other matter specified in the Rules

To get there, section 28(3) requires you to take reasonable steps to establish that an individual customer is who they claim to be, identify the customer's ML/TF risk, collect KYC information appropriate to that risk, and verify an appropriate part of it using reliable and independent data.

The Rules then set minimum KYC information by customer type: sole traders (Rule 6-1), bodies corporate, partnerships and unincorporated associations (Rule 6-2) and trusts (Rule 6-3). Our customer due diligence checklist sets these out entity by entity.

Delayed verification

Section 29 allows a reporting entity to start providing a service before completing initial CDD in limited circumstances, including where starting is essential to avoid interrupting the ordinary course of business and the additional risk is low. Under Rule 6-12, for services provided in Australia, you must still have identified the customer's risk, collected the relevant KYC information, taken reasonable steps to confirm an individual is who they claim to be, and established the identity of the customer and anyone acting for them. You must not transfer money or property for the customer before CDD is complete, and the CDD must be finished within 20 business days. Rule 6-12 does not apply where Rule 6-32 does: for a buyer in a table 6 item 1 real estate transaction, Rule 6-32 allows CDD to be completed by the earlier of 28 days after exchange of contracts and 3 days before the initially agreed settlement date.

Ongoing CDD

Section 30 requires you to monitor customers to identify, assess, manage and mitigate ML/TF risk. Where you have a business relationship, you must:

• monitor for unusual transactions and behaviours that may give rise to a suspicious matter reporting obligation
• review and, where appropriate, update the customer's risk rating when there is a significant change to the section 28(4) matters, or unusual transactions or behaviour
• review and, where appropriate, update and reverify KYC information at a frequency appropriate to the customer's risk, and whenever you doubt the adequacy or veracity of what you hold

AUSTRAC's guidance suggests your policies also name other triggers, such as a sudden and unexplained increase in transaction volumes, changes in the customer's business model, or changes in corporate structure or beneficial owners. For an accounting firm, the annual engagement rollover is a natural point to confirm nothing has changed.

Enhanced CDD

Section 32 requires enhanced CDD measures appropriate to the customer's risk where any of these apply:

• the customer's ML/TF risk is high
• a suspicious matter reporting obligation has arisen and you propose to keep providing designated services
• the customer, a beneficial owner, a person on whose behalf the customer is receiving the service, or someone acting for the customer is a foreign politically exposed person
• any of those persons is physically present in, or (for an entity) was formed in, a high risk jurisdiction for which the Financial Action Task Force has called for enhanced due diligence
• the service is part of a nested services relationship
• the customer is of a kind specified in the Rules

Where enhanced CDD applies because of high risk, a suspicious matter or a high-risk jurisdiction, Rule 6-21 requires you to establish the source of the customer's wealth and the source of the customer's funds, where relevant to the nature of the risk.

Simplified CDD

Section 31 permits simplified measures only where the customer's risk is low, enhanced CDD does not apply, and you meet the Rules. Under Rule 6-17, matters such as the identity of beneficial owners or persons acting for the customer can be taken as established where you have collected KYC information appropriate to the risk and have no reasonable grounds to doubt it. Rule 6-18 provides a beneficial owner shortcut where the customer is, or is controlled by, an entity overseen by a prudential, insurance or investor protection regulator through registration or licensing, or a strata or community title owners corporation. Customers that are, or are controlled by, a government body are now dealt with in Rule 6-7. Your policies must cover how you apply simplified measures (Rule 6-16).

Existing clients: pre-commencement customers

Under section 36, a customer whose relationship with you involved only table 6 services (among certain others) as at the start of 1 July 2026 is a pre-commencement customer. You do not have to perform initial CDD on them until a suspicious matter reporting obligation arises, or there is a significant change in the nature and purpose of the relationship that results in the customer's risk being medium or high. You must monitor these relationships for that kind of change (section 30(2)(d)). A new designated service for an existing client may be that change, so assess it when it happens.

Beneficial owners

The Act defines a beneficial owner of a non-individual as an individual who ultimately owns, directly or indirectly, 25% or more of the entity, or who controls it directly or indirectly. Control matters as much as ownership. In a family group this often points to the person who can appoint and remove the trustee or who directs the corporate trustee, not just the shareholders.

For companies and partnerships, Rule 6-2(3) requires you to collect at least KYC information about the ownership and control structure. If you take all reasonable steps but cannot identify any beneficial owner, Rule 6-8 lets you instead identify and verify the chief executive officer (or equivalent), provided you record the steps and difficulties. For trusts, Rule 6-3(5) requires the control structure and the identity of any settlor, appointor, guardian or protector. For a listed public company subject to disclosure requirements, Rule 6-7 treats beneficial owners as established.

AUSTRAC says you verify a beneficial owner's identity the same way you would verify an individual's, and suggests cross-referencing documents such as trustee resolutions (AUSTRAC, Initial CDD for trust).

Politically exposed persons and sanctions

Initial CDD must establish whether the customer, beneficial owners, persons acting for the customer and persons on whose behalf they act are PEPs or are designated for targeted financial sanctions (section 28(2)(e)). AUSTRAC suggests checking PEP status through reliable online sources, official data or third-party screening, and checking sanctions against the DFAT Consolidated List (AUSTRAC, Initial CDD for individuals).

The treatment depends on the kind of PEP:

PEP type	Enhanced CDD	Source of wealth and funds of the PEP	Senior manager approval
Foreign PEP	Always (s 32(c))	Required (Rule 6-23)	Required (AUSTRAC senior managers quick guide)
Domestic PEP	If the customer's risk is high (s 32(a))	Required where risk is high (Rule 6-23)	Required where the customer's risk is high (AUSTRAC senior managers quick guide)
International organisation PEP	If the customer's risk is high (s 32(a))	Required where risk is high (Rule 6-23)	Required where the customer's risk is high (AUSTRAC senior managers quick guide)

If an existing customer, beneficial owner or person on whose behalf the customer receives the service becomes a foreign PEP, or a domestic or international organisation PEP where risk is high, you must review and where appropriate update and reverify their KYC information (Rule 6-24).

Reporting to AUSTRAC

Report	When it applies	Deadline
Suspicious matter report (SMR), terrorism financing	Suspicion on reasonable grounds relating to terrorism financing	Within 24 hours of forming the suspicion
Suspicious matter report (SMR), other matters	For example, you suspect on reasonable grounds that a person is not who they claim to be	Within 3 business days of forming the suspicion
Threshold transaction report (TTR)	A transaction involving physical currency of A$10,000 or more	Within 10 business days after the day of the transaction
Annual compliance report	All reporting entities	As set by AUSTRAC

Source: AUSTRAC factsheet for tranche 2 reporting entities. Most firms never handle cash at that level, but if your trust account accepts physical currency for a designated service, a TTR applies.

Tipping off

Section 123 of the Act, as replaced in 2024, makes it an offence for a reporting entity, or its officers, employees or agents, to disclose that an SMR has been or must be given (or the contents of one) where the disclosure would or could reasonably be expected to prejudice an investigation. It is immaterial whether an investigation has started. The maximum penalty is imprisonment for 2 years or 120 penalty units, or both.

There is a specific exception for qualified accountants and accounting firms (section 123(4)). A disclosure about an SMR is not an offence where it relates to the affairs of a customer and is made in good faith to dissuade the customer from engaging in conduct that constitutes, or could constitute, an offence. The person relying on the exception bears an evidential burden, so record why and how the conversation happened.

In practice: keep SMR decisions within the compliance officer and those who need to know, and train client-facing staff on what not to say if a client asks why a job has paused.

Record keeping

You must make and keep accurate and complete records of your AML/CTF program and compliance activities. For most obligations, records must be retained for 7 years (AUSTRAC factsheet). That includes CDD records, risk assessments, senior manager approvals and the steps taken where a beneficial owner could not be identified (Rule 6-8 requires these steps to be recorded).

What happens if a firm does not comply?

AUSTRAC lists the same enforcement tools for every reporting entity, and accounting firms that provide designated services are reporting entities. The tools are infringement notices, remedial directions, written notices requiring an external audit, enforceable undertakings, and Federal Court proceedings for civil penalty orders and injunctions.

Tool	What it does
Infringement notice	A set penalty for missing certain obligations, including enrolment, the compliance officer, the AML/CTF program, customer due diligence, reporting and record keeping. Notices may be made public.
Remedial direction	A written instruction to take specific steps to comply, prevent a repeat breach or lodge an overdue report.
External audit notice	Requires an external auditor to review compliance or carry out an ML/TF risk assessment. AUSTRAC receives a copy of the report.
Enforceable undertaking	A written commitment to take specified actions, enforceable in the Federal Court if breached.
Civil penalty order	Ordered by the Federal Court. The maximum is 100,000 penalty units for a body corporate and 20,000 penalty units for other persons.

The value of a penalty unit depends on when the contravention happened. It is $364 for contraventions on or after 1 July 2026, set by the Crimes (Amount of a Penalty Unit) Instrument 2026, and $330 for contraventions from 7 November 2024 to 30 June 2026 (ATO, Penalty units). At $364, 100,000 penalty units is $36.4 million. Some AUSTRAC pages still show older amounts, so check the date of the conduct against the current table. For a small firm the practical risk is less about the maximum and more about the cheaper tools: a missed enrolment or a CDD file that cannot be produced is exactly what an infringement notice or remedial direction is built for.

Worked example 1: a family group with a discretionary trust and a company

The Nguyen family group has been with your firm for eight years. You prepare tax returns for Minh and Lan Nguyen, the Nguyen Family Trust (a discretionary trust) and Nguyen Holdings Pty Ltd, the corporate trustee. Minh and Lan are the two directors and 50/50 shareholders, and Minh is the appointor.

Before 1 July 2026 and today, compliance only. The group receives tax return and BAS work only. None of that is in table 6, so on the narrow reading there is no designated service and no CDD obligation from that work alone.

The trigger. In September 2026, Minh asks you to set up a new company, Nguyen Property Pty Ltd, register it with ASIC, and act on the group's purchase of a warehouse. Setting up the company is item 6. Acting on the property purchase, once you are instructed and directly advancing the transaction, is item 1. If you hold the deposit in your trust account, item 3 may apply as well.

Who is the customer. AUSTRAC says that for a company formation the customer is the proposed beneficial owners and directors. For the property purchase, the customer is whichever entity is buying.

What you establish before you start:

• Minh and Lan as individuals: full name, other names, date of birth, residential address, and an identifier. Verify name and date of birth from photo ID, and take reasonable steps to confirm each is the person they claim to be, such as matching their face against the photo ID (AUSTRAC, Initial CDD for individuals).
• If the trust is the buyer: the trust's full name, kind of trust (discretionary), principal place of business, evidence of existence, powers that govern it, the trustee (Nguyen Holdings Pty Ltd), the beneficiaries or a description of each class, and the control structure including the appointor (Rule 6-3). Verify against the trust deed and any deeds of variation.
• Nguyen Holdings Pty Ltd as trustee and person acting for the trust: the company's KYC under Rule 6-2, including its ACN, registered office, directors and director identification numbers, and the ownership and control structure.
• Beneficial owners: Minh and Lan each own 50% of the trustee company and Minh controls the trust as appointor. Both are beneficial owners.
• PEP and sanctions screening on Minh, Lan and any other beneficial owners.
• Nature and purpose: buying a commercial property for the family's business.

Risk rating. An Australian family, known to the firm for years, buying a local property with funds from their own business: likely low or medium. If the deposit were coming from an unexplained offshore source, you would consider a higher rating and enhanced CDD, including source of funds.

The existing relationship. Because the group previously received only non-designated work, it is worth recording in the file when designated services started and the CDD completed at that point.

Worked example 2: setting up an SMSF with a corporate trustee

Priya and Daniel Walsh, both new clients, ask your firm to establish a self-managed super fund with a new company, Walsh Super Pty Ltd, as trustee. You will register the company with ASIC and prepare and settle the trust deed.

Designated services. Registering the company and preparing and executing the SMSF trust deed are both creation of a body corporate or legal arrangement under item 6. AUSTRAC's own example says the accountant who drafts and facilitates execution of an SMSF trust deed provides a designated service from the point they accept and act on instructions. A financial adviser who only recommended the accountant does not.

Who is the customer. For the new company, AUSTRAC says the customer is the proposed beneficial owners and directors, Priya and Daniel. For the trust deed, table 6 item 6 of the Act says that where the service is creating an express trust, the customers include the trustee, settlor and beneficiaries of the trust.

What you establish before you start:

• Priya and Daniel's identity, verified from photo ID with a check that each is the person they claim to be.
• Their role as proposed directors and shareholders of Walsh Super Pty Ltd, and as members of the fund.
• The control structure of the fund once established: the corporate trustee and its directors.
• PEP and sanctions status for each of them.
• Nature and purpose: establishing a fund for their retirement savings.

A point on simplified CDD. Rule 6-18 allows a beneficial owner shortcut for entities overseen by a prudential, insurance or investor protection regulator through registration or licensing. AUSTRAC's trust guidance points to searching ASIC's professional registers when checking regulatory oversight. A newly established SMSF that you are creating is not an existing regulated entity you can rely on for this purpose, so plan to identify and verify the individuals.

How Nagaris supports the client-facing CDD steps

Nagaris handles the client-facing side of onboarding. The client fills in one form on their phone with their details, AML questions and the declaration, and verifies their ID through their bank (ConnectID) or with photo ID and a selfie. Your team then sees the ID result, PEP, sanctions and adverse media screening and company checks side by side on one screen. Risk factors fill in from the screening and answers, you confirm the rating, and the next review date is set. Business clients get KYB with ASIC extracts, directors and beneficial owners. ID checks are $5 a person and company checks start from $9.

Nagaris is a compliance technology platform. It does not provide legal advice and does not replace your firm's AML/CTF program. Your firm remains responsible for its risk assessment, policies, compliance officer, CDD decisions and reports to AUSTRAC. See AML/CTF software for more.

Next steps

1. List the services your firm provides and mark each against table 6.
2. If any are designated services, check you enrolled within 28 days of first providing one.
3. Designate a compliance officer who meets section 26J.
4. Work through the AUSTRAC accountant program starter kit and our Tranche 2 readiness checklist.
5. Use the customer due diligence checklist for each new designated service engagement.

Questions

When did AML/CTF obligations start for accountants?

AUSTRAC states obligations apply to tranche 2 entities, including accountants, from 1 July 2026.

When must an accounting firm enrol with AUSTRAC?

Within 28 days of first providing a designated service. AUSTRAC says this is typically 29 July 2026 for services provided from 1 July 2026.

Is preparing a tax return a designated service?

Tax return preparation is not one of the nine professional designated services in table 6 of section 6 of the Act. Obligations attach when you provide a listed service, such as setting up a company or trust or acting on the sale of a business.

Is setting up an SMSF a designated service?

AUSTRAC's guidance gives the example of an accountant who drafts and facilitates execution of an SMSF trust deed providing a designated service under item 6 from the point they accept and act on instructions.

How quickly must a suspicious matter report be lodged?

Within 24 hours of forming the suspicion for terrorism financing, and within 3 business days for other matters, according to AUSTRAC.

Do I need to redo CDD on existing clients?

Not for pre-commencement customers under section 36 of the Act, until a suspicious matter reporting obligation arises or a significant change in the relationship results in medium or high risk.

Sources

• AUSTRAC: Accountants
• AUSTRAC: Professional designated services
• AUSTRAC: AML/CTF obligations factsheet for tranche 2 reporting entities
• AUSTRAC: Check if you may be regulated
• AUSTRAC: Initial CDD for individuals
• AUSTRAC: Initial CDD for trust
• AUSTRAC: Reviewing and updating customers' ML/TF risk and KYC information
• AUSTRAC: Governance quick guide for senior managers
• Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (No. 110, 2024)
• Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (F2025L01026)
• Anti-Money Laundering and Counter-Terrorism Financing Act 2006, Compilation No. 63 (1 October 2026)
• AML/CTF Rules 2025, Compilation No. 1 (31 March 2026)
• AUSTRAC, Consequences of not complying
• AUSTRAC, AML/CTF transitional rules 2026
• Crimes (Amount of a Penalty Unit) Instrument 2026
• ATO, Penalty units