From 01 July 2026, Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws will expand to include certain services provided by accountants and other professional advisers.

While this is a significant regulatory change, it’s important to understand that these obligations do not apply to all accounting services. Instead, they apply only where specific types of work – known as designated services – are provided.

This article explains what’s changing, when it applies, and what it may mean for you as a client.

What is changing?

The AML/CTF regime, overseen by AUSTRAC, is being extended to cover a wider range of “gatekeeper” professions – including accountants – who may be involved in higher-risk financial transactions or structuring work.

From 01 July 2026, accounting firms that provide certain designated services will be required to:

• enrol with AUSTRAC. 
• maintain an AML/CTF compliance program. 
• verify client identity and conduct due diligence.
• monitor and, where required, report certain activities.

These reforms are designed to help prevent criminals from using legitimate businesses to move or disguise illicit funds.

Not all accounting services are affected

A key point – and one many clients misunderstand – is that AML/CTF obligations do not apply simply because you engage an accountant.

They only apply where your adviser is providing a designated service.

This means many everyday services remain unchanged, such as (but not limited to):

• tax return preparation 
• BAS and compliance work
• general accounting advice.

Two accounting firms, or even two engagements with the same firm, may have very different obligations depending on the nature of the service being provided.

What are “designated services”?

Designated services are specific types of work identified in the legislation because they carry a higher risk of being used for financial crime.

For accounting firms, these can include services such as:

• assisting with the sale or purchase of a business, company or real estate. 
• helping establish or restructure companies or trusts. 
• managing or controlling client funds or assets. 
• assisting with financing arrangements (debt or equity). 
• acting on behalf of a client in certain roles (e.g. company officeholder or nominee). 
• assuming the role as your registered business office (address) after 01 July 2026.

In simple terms, if the work involves setting up, moving, or managing money, managing or changing entity structures or ownership, it is more likely to be a designated service.

What this means for you as a client

If you engage us for a designated service, there are a few important changes to be aware of.

1. Identity checks before work can begin

Before we can start work for you on a designated service, we are required to carry out customer due diligence (CDD).

This includes verifying:

• your identity.
• any entities involved (such as companies or trusts).
• the individuals who ultimately own or control those entities (beneficial owners).

In practice, this means we may ask you to provide identification documents or confirm ownership structures before work commences.

2. Ongoing information requirements

AML/CTF obligations don’t stop once an engagement begins.

If there are changes during the course of the engagement – such as:

• a change in scope.
• a new or additional designated service.
• changes in ownership or structure

we may need to collect additional information or update our records.

This ongoing monitoring is a key part of the framework and ensures that risks are appropriately managed throughout the engagement.

3. Some services may pause until information is provided

To meet our legal obligations, there may be circumstances where we are unable to proceed with a designated service until required information has been received and verified.

While this can occasionally feel like an extra step, it is a mandatory requirement under the legislation and applies consistently across all regulated firms.

Why these changes are being introduced

The expansion of AML/CTF laws is aimed at strengthening Australia’s financial system and reducing the risk of:

• money laundering.
• terrorism financing.
• organised financial crime.

These reforms bring Australia in line with international standards and close gaps that criminals have historically used to move funds through legitimate professional services.

What you can expect from us

Our approach is to make this process as straightforward as possible for you. Where AML/CTF requirements apply, we will:

• clearly explain what information is needed and why.
• keep requests targeted and relevant to the engagement.
• work with you to avoid unnecessary delays.
• maintain strict confidentiality and data security.

Most importantly, we will continue to guide you through the process so you can proceed with confidence.

Final word

The introduction of AML/CTF Tranche 2 is a significant change – but for most clients, the impact will be limited to specific types of engagements.

The key takeaway is simple: AML/CTF obligations apply based on the service being provided – not just because you are working with an accountant. 

If you’re unsure whether your current or upcoming work may involve a designated service, we’ll help by clarifying any new processes we need to undertake, what we need from you, and when we can commence your work under these new AML/CTF laws.

As always, feel free to reach out to our accounting professionals if you have any questions.