From 1 July 2026, Australian accounting practices providing designated services are reporting entities under AUSTRAC’s expanded AML/CTF regime. Here’s what you need to know — and do.
The AML/CTF regime does not regulate accountants as a profession — it regulates specific services. Whether your practice is captured by Tranche II depends entirely on whether you provide one or more designated services that directly advance a transaction involving money, property, or the creation of legal structures on behalf of a client.
Your accounting practice is likely in scope if it assists clients with any of the following:
AUSTRAC has confirmed the following accounting activities are generally outside the designated services definition:
Important: The boundary matters. If your advisory work leads directly to executing a transaction — even if the transaction execution itself is handled by another party — AUSTRAC may consider you to be providing a designated service. When in doubt, a professional scope assessment is strongly recommended before 31 March 2026.
One of the most common misconceptions among accounting practices is that small or boutique firms will not be targeted. AUSTRAC’s position is clear: if you provide a designated service in the course of carrying on a business with a geographical link to Australia, the obligation is yours — regardless of firm size, turnover, or how infrequently the service is provided. A sole practitioner providing trust structuring advice once a year is still a reporting entity if that advice directly advances the transaction.
AUSTRAC has confirmed that even work provided at no charge — including pro bono services for family members, friends, or community organisations — can be captured if it involves providing a designated service in the course of carrying on a business. The test is the nature of the service, not whether a fee is charged.
| Obligation | What It Means for Your Practice |
|---|---|
| Enrol with AUSTRAC | Register via the AUSTRAC Business Portal from 31 March 2026. Deadline: 29 July 2026. |
| ML/TF Risk Assessment | Identify and document your money laundering and terrorism financing risks — tailored to your clients, services, and geographies. |
| AML/CTF Program | A written, risk-based compliance program covering your policies, procedures, controls, and staff training obligations. |
| Customer Due Diligence (CDD) | Identify and verify every client before providing a designated service. Enhanced checks required for high-risk clients and Politically Exposed Persons (PEPs). |
| Ongoing Monitoring | Continuously monitor client relationships and transactions for suspicious activity throughout the engagement. |
| Suspicious Matter Reporting | File Suspicious Matter Reports (SMRs) with AUSTRAC promptly when required. Failure to report is a serious criminal offence. |
| Record Keeping | Retain identity verification and transaction records for a minimum of seven years. |
| Appoint a Compliance Officer | Designate a qualified AML/CTF compliance officer and notify AUSTRAC by 29 July 2026. |
| Date | Milestone |
|---|---|
| 31 March 2026 | AUSTRAC enrolment portal opens for Tranche II entities. |
| 1 July 2026 | All AML/CTF obligations commence. Your program must be fully operational from this date. |
| 29 July 2026 | Final deadline to complete AUSTRAC enrolment and notify your nominated compliance officer. |
FATF has long identified accounting professionals as a key vulnerability in the global AML/CTF framework. Accountants are exploited because of their technical expertise, professional credibility, and access to client financial structures. Common methods include:
Australia has been on FATF’s watch list in part because of the failure to regulate accounting professionals. Tranche II closes that gap permanently as of 1 July 2026.
WilliamThomas&Co. offers a no-obligation Tranche II scoping consultation. With less than four months to the 1 July 2026 deadline, early action is the only safe strategy.