AML/CTF Guide for Accountants in Australia

Part 1

When AML/CTF May Apply

From 1 July 2026, some transaction, client-property, company, trust and nominee services provided by accountants are designated services. For the relevant table 6 items, the assistance must directly advance the relevant transaction or creation or restructure; general advice or ancillary work alone is not enough.

• Helping plan or carry out a sale, purchase or transfer of real estate, a company or a legal arrangement.
• Receiving, holding, controlling or managing client property for a relevant transaction.
• Helping arrange equity or debt finance for a company or legal arrangement.
• Creating or restructuring a company, body corporate, trust or other legal arrangement.
• Selling or transferring a shelf company.
• Acting, or arranging for another person to act, as a director or secretary, under a power of attorney, as a partner, as trustee of an express trust or in an equivalent role for a nominator.
• Acting, or arranging for someone to act, as a nominee shareholder for a nominator.
• Providing a registered office, principal place of business or address service where the statutory conditions are met.

Part 2

Main Risks in This Sector

These are starting points, not a ready-made risk rating. The business still needs to assess its own customers, services, countries, channels, transactions and technology.

• Companies, trusts or nominees can hide the person who really owns or controls assets.
• Client money and transaction work can move value quickly through a trusted professional.
• Shelf companies, registered offices and restructures can give a false appearance of legitimacy.
• Third-party funding, unexplained wealth and high-risk country links may not fit the client’s profile.
• Long-standing clients can be treated as familiar even when the service or ownership has changed.

Part 3

A Practical Control Plan

1. Step 1

   Confirm scope

   List every service the practice provides and map possible designated services to section 6.

2. Step 2

   Build the customer process

   Separate covered workflows from ordinary tax, bookkeeping and assurance work.

3. Step 3

   Set the risk controls

   Build CDD and approval points into engagement acceptance, transaction work and client-money processes.

4. Step 4

   Train and connect people

   Train partners and staff to recognise hidden ownership, unusual funding and suspicious instructions.

5. Step 5

   Test and improve

   Test a sample of new matters and keep the scope decision, CDD and reasons together.

Part 4

Worked Examples

These examples show how the scope and risk questions can be joined. They do not replace the law or the facts of a real matter.

Part 5

Evidence That Should Be Easy to Find

• The designated-service and geographical-link analysis.
• The current sector risk assessment and the official sources used.
• A service map that distinguishes designated and non-designated accounting work.
• Engagement files linking the scope decision, CDD, risk rating and approval.
• Registers for client money, company or trust formation and nominee services.
• Training examples drawn from the practice’s actual service lines.
• Customer, beneficial ownership, risk, monitoring and reporting records.
• Training, internal review, independent assurance and remediation records.

Part 6

Common Mistakes

• Assuming every accounting engagement is regulated.
• Assuming tax or bookkeeping work can never sit beside a designated service.
• Accepting a client’s company chart without finding the individuals behind it.
• Completing CDD after transaction work has already started without a lawful basis.
• Using the professional relationship as a substitute for source and purpose checks.