Australia AML/CTF Tranche 2: What Accountants Must Do

From 1 July 2026, many Australian accounting firms became "reporting entities" under the country's anti-money laundering and counter-terrorism financing (AML/CTF) regime. This was the long-awaited second tranche of reforms, which extended the rules beyond banks and casinos to lawyers, accountants, real estate agents, conveyancers and trust and company service providers. If your firm advises on company or trust structures or handles client money, you need to know whether you are caught, how to enrol with AUSTRAC (the Australian Transaction Reports and Analysis Centre), and what to have in place. This guide summarises the position as reported by compliance commentators at the time of writing. Check AUSTRAC's own pages before you act, because enrolment and guidance details are still developing.

What changed on 1 July 2026

Tranche 2 commenced on 1 July 2026 under the AML/CTF Act, according to a NameScan summary of the reforms. AUSTRAC opened enrolment for newly regulated businesses on 31 March 2026. AUSTRAC estimates that around 80,000 new entities are in scope across the sectors added, according to Zyphe's summary of the reforms. Compliance is expected to be risk-based and proportionate, and AUSTRAC has signalled an education-first approach for small businesses making honest mistakes.

Are you caught? It depends on the service, not the job title

The most important point for accountants is that the law attaches to "designated services", not to the title "accountant". Commentary on the reforms says an accountant is regulated when providing one or more designated services such as:

• helping to create, operate, manage or restructure a company, trust or other legal arrangement;
• managing client money or assets where that forms part of a designated service;
• arranging equity or debt financing where it is a designated service; and
• assisting with changes in ownership or control of a business.

The same commentary says that general tax return preparation, routine bookkeeping and general advice are not designated services on their own. A firm that only does compliance work for existing clients may therefore fall outside the regime, while a firm that sets up trusts for clients is inside it. Map your services against the designated services in the Act, and keep a note of your reasoning.

Enrolling with AUSTRAC

Businesses must enrol with AUSTRAC within 28 days of providing a designated service, according to AUSTRAC's factsheet for tranche 2 reporting entities. AUSTRAC says this will typically be 29 July 2026 for the new designated services. That date has now passed, so enrol immediately if you have not done so. Firms already providing designated services without enrolling should enrol as soon as possible and keep a record of what they did and when.

What obligations apply from day one

Based on AUSTRAC's factsheet and the commentary we reviewed, the main obligations for a newly regulated accounting firm are:

• AML/CTF program. A documented, risk-based program that identifies and assesses money laundering and terrorism financing risks for your clients, services and delivery channels.
• Customer due diligence (CDD). Verify identity and identify beneficial owners before providing the designated service, screen for sanctions and politically exposed persons (PEPs), and apply enhanced due diligence where risk is higher. CDD continues throughout the engagement.
• Suspicious matter reports (SMRs). Report suspicion to AUSTRAC. According to AUSTRAC, SMRs are due within three business days of forming the suspicion, or within 24 hours where terrorism financing is suspected. There is no monetary threshold.
• Threshold transaction reports. AUSTRAC says a transaction involving physical currency of A$10,000 or more (or the foreign currency equivalent) must be reported within ten business days after the transaction.
• Record-keeping. Keep identification records, beneficial ownership findings, risk assessments and service records for seven years, which AUSTRAC gives as the retention period for most obligations.
• AML/CTF compliance officer. Appoint a named person and notify AUSTRAC. NameScan reports the later of 29 July 2026 or 14 days after enrolment.

Staff training and independent evaluation of the program are also expected, according to Zyphe.

A practical plan for a small firm

1. Scope your services. List what you do and decide which are designated services.
2. Enrol. Register with AUSTRAC online if any are, and record the date.
3. Run a risk assessment. Consider client types, trust and company structures, overseas links, cash and complex ownership.
4. Write the program. Keep it short and tied to how you actually work.
5. Update engagement letters. Tell clients that you must verify identity and may need to report.
6. Train the team. Make sure everyone can spot a suspicious matter and knows who to tell.

If your firm operates in several countries, our guides to AML supervision for accountancy firms in the UK and Ireland and firm-wide AML risk assessment show how the same ideas work elsewhere and how to structure a risk assessment.

How Australia compares with other regimes

Australia's approach is broadly in line with the Financial Action Task Force (FATF) recommendation that accountants be regulated when they carry out specified activities for clients. Accountants in the UK and Ireland have been supervised for years and the mechanics will feel familiar: risk assessment, CDD, reporting to a financial intelligence unit and record-keeping. The difference is in the detail. For example, Australia uses suspicious matter reports and AUSTRAC enrolment, while the UK uses suspicious activity reports through the National Crime Agency. See our guide to suspicious activity reports for the principles that carry across.

Frequently asked questions

Do all Australian accountants have to enrol with AUSTRAC?

No. Only those providing designated services need to enrol. Firms limited to tax returns, routine bookkeeping and general advice are described as outside the regime, but you should confirm with AUSTRAC's guidance.

Who supervises accountants under the new regime?

AUSTRAC is the AML/CTF regulator and financial intelligence unit and is the body to enrol with.

Can an accountant tell a client they filed a suspicious matter report?

Generally no. As in most regimes, tipping off is prohibited, so staff should be trained to avoid disclosing a report.

What is the penalty for not complying?

The summaries we reviewed do not give penalty amounts. Check the AML/CTF Act and AUSTRAC's published enforcement approach before you advise a client.