As of 1 July 2026, accounting firms that provide certain services will be caught in an expanded rollout of the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006. These rules are regulated by AUSTRAC, whose role is to detect, deter and disrupt money laundering, terrorism financing, and serious and organised crime. This extended rollout will also impact other industries including lawyers, real estate professionals and other service providers that perform certain higher-risk activities.

Where an accounting firm provides a designated service, it becomes a ‘reporting entity’ and will be required to comply with a range of AML/CTF obligations. You may have already seen AML/CTF requirements in action when:

• applying for finance or opening a new bank account, banks conducting identity verification checks to confirm your identity
• certain cash transactions exceeding $10,000 are routinely reported to AUSTRAC
• monitoring of usual transactions that appear in your bank account.

Accounting firms under the new AML/CTF will be required to undertake the following processes:

• Know Your Client (KYC) identification and verification procedures
• identify if an individual is classified as Politically Exposed Person creating a higher risk of undue influence
• risk assessments for clients and services provided
• record-keeping requirements
• reporting obligations to AUSTRAC where required
• a documented risk appetite framework to facilitate onboarding and offboarding of clients

This means that when we provide certain designated services, we are required to collect additional information and complete specific verification processes before we can proceed.

What is the impact on existing clients?

For any existing clients, we are expecting the impact will be minimal although it may result in some ongoing administration compliance. The requirements will have most impact on these areas:

• new clients engaging us for designated services
• changes in existing clients’ services that fall within the designated service categories or require further identification checks
• client groups where one entity triggers AML/CTF obligations, this may have a knock-on effect to other entities.

How will we monitor these reporting requirements?

Software used by our firm will have functions available from 1 July 2026 to meet KYC and AML/CTF identity checking obligations. This will ensure our compliance required by the regulations. Clients may be asked to:

• complete a client identification form
• provide proof of identity documents i.e. passport, driver's licence
• undergo screening for Politically Exposed Person (PEP), sanctions, adverse media screening
• if we do not already have copies – provide trust deeds, company constitutions, permanent entity documents
• assist with providing individual details who directly or indirectly owns or controls 25% or more of a company or trust, and not a client of our firm
• provide information regarding the source of funds or source of wealth where appropriate.

Services that will trigger AML/CTF requirements

There are nine designated services applicable to the accounting profession, and these are the ones most likely to impact our firm:

1. Assisting in the planning or execution of the sale, purchase or transfer of a company or legal arrangement (Item 2)

Examples include:

• business acquisitions or disposals
• company share transfers
• trust ownership changes.

2. Assisting in the creation or restructuring of a company or legal arrangement (Item 6)

Examples include:

• company and trust establishments
• changes to shareholdings, appointment/removal of directors and officeholders
• corporate restructures and ownership changes lodged with ASIC.

3. Providing a registered office address or principal place of business address (Item 9)

This generally applies where our firm provides a registered office address or principal place of business address for a company.

The following designated services are generally not provided by our firm and do not expect to attract any compliance requirements:

• assisting with real estate transactions (Item 1)
• receiving, holding, controlling or managing client funds or property for transactions (Item 3)
• assisting with equity or debt financing transactions (Item 4)
• selling or transferring shelf companies (Item 5)
• acting as, or arranging, directors, trustees, company secretaries or nominee shareholders (Items 7–8).

Final comments

These new requirements will unfortunately trigger extra compliance and may delay what normal processing timeframes would be for certain services. There will also be a cost to undertake these checks to ensure we meet the compliance requirements.

There is some uncertainty around how detailed some of the identification process needs to be, especially in the instance of family trusts that can have wide ranging beneficiaries and no fixed distribution percentages.

These measures are designed to help protect Australia's financial system. It will at times cause inconvenience which we hope to minimise for our clients as much as possible.

If you wish to discuss this further, please contact us. You can find more information on the AUSTRAC website.