AML/CTF Tranche 2: what changed for accountants on 1 July 2026

On 1 July 2026 accountants, tax agents and other professional service providers became reporting entities under Australia’s anti-money laundering and counter-terrorism financing regime, to the extent they provide designated services, such as company formation, trust establishment, registered office and nominee director arrangements. Tax return, BAS and bookkeeping work alone is not a designated service. It is the most significant regulatory change to affect the accounting profession in a generation. The Tranche 2 reforms brought accountants, lawyers, real estate agents and other gatekeepers into the framework that has applied to banks and financial institutions since the AML/CTF Act commenced in 2006. This article was written before commencement and has been updated to reflect the position now that the obligations are live.

The obligations apply to anyone providing a designated service. For accountants, the relevant services include assisting with the planning or execution of, or otherwise acting for a client in, the formation or restructuring of a company, partnership or trust; acting as, or arranging for another person to act as, a director, secretary, trustee or nominee shareholder; providing a registered office address or principal place of business address; assisting with the buying or selling of a body corporate or real property; selling or transferring a shelf company; assisting with equity or debt financing for a company or trust; receiving, holding or managing client money or property as part of a transaction; and acting as, or arranging, a partner in a partnership or a power of attorney for a company or trust.

If you are reading this, your firm almost certainly provides at least one of them. Company formation, trust establishment and registered office services are all clearly in scope. The obligation attaches to the service, not to the type of entity being formed, so every company registration, every trust deed, every registered office arrangement and every nominee director appointment now carries AML/CTF obligations.

The practical obligations are: enrolling with AUSTRAC as a reporting entity, having a money laundering and terrorism financing risk assessment and AML/CTF policies in place, appointing an AML/CTF compliance officer, conducting initial customer due diligence before providing a designated service, conducting ongoing customer due diligence, training staff on the obligations and on the tipping-off offence, and reporting suspicious matters and threshold transactions to AUSTRAC.

Two points on enrolment are worth getting right, because both are commonly misstated. First, the word: accounting and legal practices enrol with AUSTRAC. Registration is a separate, additional process that applies principally to remittance service providers and virtual asset service providers, and most professional firms will never need it. Second, the timing: a firm generally applies to enrol no later than 28 days after it starts providing a designated service, but that is a deadline for the administrative act of enrolling, not a grace period on the substantive obligations. Customer due diligence and the policy framework are required from the point the service is provided.

The program structure is also not what the pre-commencement commentary described. The old framework split the program into a mandatory Part A, the firm-wide risk management framework, and a Part B, the customer identification procedures. That division is no longer how the obligation is framed. The current framework requires a risk assessment of the business plus AML/CTF policies responding to the risks it identifies. AUSTRAC’s starter kit for accountants is organised around three documents: a risk assessment, a policy document, and a process document, which is a sensible shape for most practices to follow.

Customer due diligence is the obligation with the most immediate effect on day-to-day practice. Before providing a designated service to a new customer, you need to identify the customer and verify their identity on reliable and independent information, understand their ownership and control structure including beneficial owners, screen for sanctions and politically exposed persons, assess the customer’s risk, and keep records of what you did and why.

Existing customers are handled differently from new ones. Customers you were already providing table 6 services to at 1 July 2026 are pre-commencement customers, and full initial due diligence is not required for them. That changes if a suspicious matter reporting obligation arises, or if there is a significant change in the nature and purpose of the relationship (for example a materially different new service) that makes the customer medium or high risk. In either case initial due diligence must be done. Ongoing due diligence still applies to these customers.

The connection to corporate secretarial work is direct. Registered office services, nominee director and company secretary appointments, and company and trust formations or restructures are designated services. Routine ASIC lodgements and register maintenance are not designated services on their own, though they are often provided alongside services that are. Outsourcing does not usually take your firm out of scope. If you assist a client to set up a company or trust, or arrange for a provider to act as director, secretary or nominee shareholder, your firm is itself providing a designated service, and the provider is also providing one. Both of you have obligations for the same customer. A reliance arrangement means the customer only has to be verified once.

Where reliance helps is in avoiding duplication. Where your firm has done customer due diligence on a client and we are forming an entity for that same client, a reliance arrangement lets us rely on your work rather than verifying the same person twice. You can set one up once in the client portal, after which orders need only a short per-order confirmation.

One caveat on scope. We are not AML consultants and we do not prepare, review or sign off a firm’s risk assessment or AML/CTF policies, and nothing here is AML advice. For that, work with an AML specialist or your professional body. AUSTRAC’s own guidance and its starter kit for accountants are the right first stop, and they are free.