--- title: "Accounting Sector AML/CTF Compliance | HeadStart Docs" description: "Accountants AML/CTF under Tranche 2: company formations, trust services, beneficial owners. BAS and tax agents covered. Free sector report." lang: en-AU json-ld: | [ { "@context": "https://schema.org", "@type": "Organization", "name": "HeadStart Docs", "legalName": "HeadStart Docs Pty Ltd", "url": "https://www.headstartdocs.com.au", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png?v=4", "width": 512, "height": 512 }, "description": "AML/CTF compliance digital products and programs for Australian businesses under Tranche 2 regulations. Free program documents and AML Portal. 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We provide digital products for AML/CTF compliance, not legal services." } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Shop", "item": "https://www.headstartdocs.com.au/shop" }, { "@type": "ListItem", "position": 3, "name": "Tranche 2 Hub", "item": "https://www.headstartdocs.com.au/tranche-2" }, { "@type": "ListItem", "position": 4, "name": "Sanctions Search", "item": "https://www.headstartdocs.com.au/sanctions-search" } ] }, { "@context": "https://schema.org", "@type": "FAQPage", "mainEntity": [ { "@type": "Question", "name": "Do I still need a solicitor for AML/CTF Tranche 2 compliance?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. HeadStart Docs products are digital publications that give you a substantial head start, but they must be reviewed and tailored by a qualified solicitor to your specific business circumstances before implementation." } }, { "@type": "Question", "name": "How is HeadStart Docs different from the free AUSTRAC Starter Kits?", "acceptedAnswer": { "@type": "Answer", "text": "AUSTRAC Starter Kits are generic starting points that require significant customisation. HeadStart products are sector-specific, pre-populated with industry-relevant risk factors and scenarios, and include 12 months of AML Portal access for ongoing compliance including screening, record keeping and reporting tools." } }, { "@type": "Question", "name": "What if the AML/CTF rules change after I purchase?", "acceptedAnswer": { "@type": "Answer", "text": "Your digital products are yours to keep. If significant regulatory changes occur, updated versions will be available to active portal subscribers. The AML Portal itself is continuously updated to reflect current AUSTRAC requirements and sanctions lists." } }, { "@type": "Question", "name": "What happens after my 12-month AML portal access expires?", "acceptedAnswer": { "@type": "Answer", "text": "Your documentation is yours forever. To continue using the AML Portal (screening tools, compliance calendar, record keeping), you pay $35 per customer CDD. Cancel anytime — no subscription required." } }, { "@type": "Question", "name": "Is HeadStart Docs a law firm?", "acceptedAnswer": { "@type": "Answer", "text": "No. HeadStart Docs is a digital publisher and platform provider. We sell digital compliance products and portal access. We do not provide legal advice. Referrals for legal advice can be made to our related law firm, HeadStart Counsel." } }, { "@type": "Question", "name": "When does AML/CTF Tranche 2 commence in Australia?", "acceptedAnswer": { "@type": "Answer", "text": "Tranche 2 AML/CTF obligations commence on 1 July 2026. All reporting entities in designated sectors including lawyers, accountants, real estate agents, conveyancers, and trust and company service providers must have their AML/CTF programs in place by this date." } } ] }, { "@context": "https://schema.org", "@type": "Service", "serviceType": "AML/CTF Program - Accounting Professionals", "provider": { "@type": "Organization", "name": "HeadStart Docs" }, "description": "AML/CTF compliance program for accounting professionals in Australia. Includes client due diligence, risk assessment and reporting obligations under Tranche 2.", "areaServed": { "@type": "Country", "name": "Australia" }, "audience": { "@type": "BusinessAudience", "name": "Accounting Professionals" } }, { "@context": "https://schema.org", "@type": "Product", "name": "Accounting Professionals AML/CTF Program Documents", "description": "Sector-specific AML/CTF program documentation for accounting professionals under Tranche 2 regulations. Includes policies, procedures, training register and implementation support documentation.", "image": "https://www.headstartdocs.com.au/images/accounting-shop.jpg", "sku": "accounting-sole", "brand": { "@type": "Brand", "name": "HeadStart Docs" }, "category": "AML/CTF Compliance Programs", "offers": { "@type": "Offer", "price": "249", "priceCurrency": "AUD", "availability": "https://schema.org/InStock", "url": "https://www.headstartdocs.com.au/accounting", "priceValidUntil": "2027-07-01", "seller": { "@type": "Organization", "name": "HeadStart Docs" } } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Accounting Sector", "item": "https://www.headstartdocs.com.au/accounting" } ] }, { "@context": "https://schema.org", "@type": "FAQPage", "mainEntity": [ { "@type": "Question", "name": "Which accounting services trigger AML/CTF obligations?", "acceptedAnswer": { "@type": "Answer", "text": "Accountants providing designated services like company formation, trust establishment, acting as registered office, or managing client funds for transactions become reporting entities under Tranche 2. Standard tax return preparation and BAS lodgement alone are not designated services." } }, { "@type": "Question", "name": "Do BAS agents and tax agents need an AML/CTF program?", "acceptedAnswer": { "@type": "Answer", "text": "Yes, if they provide designated services beyond standard tax and BAS work, such as company formations, trust services or acting as registered agents for ASIC." } }, { "@type": "Question", "name": "What customer due diligence do accountants need to perform?", "acceptedAnswer": { "@type": "Answer", "text": "Accountants must verify client identity, identify beneficial owners of entities, assess ML/TF/PF risks and maintain ongoing monitoring of client relationships and transactions." } }, { "@type": "Question", "name": "When do accountants need to file reports with AUSTRAC?", "acceptedAnswer": { "@type": "Answer", "text": "Accountants must file Suspicious Matter Reports when they suspect money laundering or terrorism financing, and Threshold Transaction Reports for cash transactions of $10,000 or more." } }, { "@type": "Question", "name": "How much does AML/CTF compliance cost for an accounting firm?", "acceptedAnswer": { "@type": "Answer", "text": "HeadStart Docs offers free Accounting Sector AML/CTF program documents to help accounting firms get started with their compliance obligations." } }, { "@type": "Question", "name": "When does AUSTRAC enrolment open for accountants?", "acceptedAnswer": { "@type": "Answer", "text": "AUSTRAC enrolment opens 31 March 2026. All accounting professionals providing designated services must enrol by 29 July 2026. Tranche 2 obligations formally commence on 1 July 2026." } }, { "@type": "Question", "name": "Can I use the free AUSTRAC starter kit instead of buying a program?", "acceptedAnswer": { "@type": "Answer", "text": "AUSTRAC provides free starter kits but these are generic digital products with limited depth. HeadStart Docs provides sector-specific, comprehensive compliance documents including risk assessments, CDD procedures, a training register and record-keeping tools. A 45-item audit found significant content gaps in the free kits." } } ] }, { "@context": "https://schema.org", "@type": "HowTo", "name": "How to Prepare for AML/CTF Tranche 2 as an Accountant", "description": "Step-by-step guide for accounting professionals to prepare for AML/CTF Tranche 2 compliance before July 2026.", "totalTime": "P180D", "step": [ { "@type": "HowToStep", "position": 1, "name": "Identify your designated services", "text": "Review which of your accounting services are captured under Tranche 2, including company formations, trust services and registered office services." }, { "@type": "HowToStep", "position": 2, "name": "Appoint an AML/CTF Compliance Officer", "text": "Designate a senior person in your practice to oversee AML/CTF compliance and act as the primary contact with AUSTRAC." }, { "@type": "HowToStep", "position": 3, "name": "Conduct a risk assessment", "text": "Assess your practice's exposure to money laundering, terrorism financing and proliferation financing risks based on your services and client base." }, { "@type": "HowToStep", "position": 4, "name": "Develop your AML/CTF program", "text": "Create policies and procedures documents tailored to your accounting practice operations." }, { "@type": "HowToStep", "position": 5, "name": "Establish customer due diligence procedures", "text": "Implement client identification, verification, beneficial ownership identification and ongoing CDD procedures." }, { "@type": "HowToStep", "position": 6, "name": "Set up transaction monitoring", "text": "Implement systems to monitor client transactions and identify unusual patterns or suspicious activities." }, { "@type": "HowToStep", "position": 7, "name": "Train staff on AML/CTF obligations", "text": "Provide training to all staff on identifying suspicious matters, reporting obligations and compliance procedures." }, { "@type": "HowToStep", "position": 8, "name": "Enrol with AUSTRAC before July 2026", "text": "Register your practice with AUSTRAC as a reporting entity before the Tranche 2 commencement date." }, { "@type": "HowToStep", "position": 9, "name": "Set up recordkeeping procedures", "text": "Establish systems to retain AML/CTF records for the required periods (7 years for most records)." }, { "@type": "HowToStep", "position": 10, "name": "Schedule regular program reviews", "text": "Plan for annual reviews of your AML/CTF program and risk assessment to ensure ongoing compliance." } ], "author": { "@type": "Organization", "name": "HeadStart Docs" } }, { "@context": "https://schema.org", "@type": "WebPage", "name": "Accounting Sector AML/CTF Compliance", "url": "https://www.headstartdocs.com.au/accounting", "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".sector-hero-description", ".faq-section", ".compliance-obligations" ] } } ] --- We use cookies to enhance your experience and analyse traffic. [Privacy Policy](/privacy) Essential OnlyAccept All [Skip to main content](#main-content) [ ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) ](/) [Home ](/) Features [Programs ](/programs) Resources Sectors [Log in ](/auth) [Portal](/aml-landing) Accounting Sector # Accounting practices providing designated services are captured under Tranche 2. Here's what you need to know before 1 July 2026. From 1 July 2026, new AML/CTF compliance obligations (called Tranche 2) will apply to the Accounting Sector. AUSTRAC enrolment opens 31 March 2026. ![Accounting practices providing designated services are captured under Tranche 2. Here's what you need to know before 1 July 2026. professionals](/assets/accounting-office-DPcoHo6H.jpg) ## The path to 1 July 2026 is defined by clear legislative and regulatory milestones AML/CTF Amendment Act Passed Nov 2024 Finalisation of AML/CTF Rules Aug 2025 Core Guidance from AUSTRAC Oct 2025 Sector-Specific Guidance for Accountants Jan 2026 AUSTRAC Enrolment Opens 31 Mar 2026 Mandatory Compliance Commences 1 Jul 2026 AUSTRAC's national risk assessment identifies accounting services as high-risk, making them a focus of the reforms. Your preparation starts now. ## These reforms are driven by ### FATF Standards The primary driver is the Financial Action Task Force (FATF), the global standard-setter for combating financial crime. Australia is a founding member and subject to its peer reviews. ### 2015 Evaluation Gap Australia's 2015 FATF evaluation highlighted a key deficiency: the lack of regulation for "gatekeeper" professions like lawyers, accountants and real estate agents. ### Criminal Exploitation Criminals exploit these professional services to conceal illicit funds, hide beneficial ownership through complex structures and add a veneer of legality to the proceeds of crime. ### Tranche 2 Reforms The Tranche 2 reforms close this long-standing vulnerability, strengthening the integrity of Australia's financial system. ## ML/TF/PF Risks in the Accounting Sector The accounting sector faces unique money laundering (ML), terrorism financing (TF) and proliferation financing (PF) risks. If an entity offers designated services, they will need to be aware of and assess the risks in relation to their business and services offered. #### Fraudulent Financials Manipulated statements Preparation of misleading financial statements to support loan applications or investment fraud. #### Invoice Layering Trade-based laundering Complex invoice arrangements designed to move money through legitimate-appearing business transactions. #### Third-Party Instructions Unusual payment requests Clients requesting payments be made to or received from unexpected third parties. #### High-Risk Jurisdictions Cross-border transactions Funds flowing through jurisdictions with weak AML controls or known for financial crime. ### Industry References [NRA: Money Laundering (2024) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/money-laundering-australia-national-risk-assessment-2024)• [NRA: Terrorism Financing (2024) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/terrorism-financing-australia-national-risk-assessment-2024)• [NRA: Proliferation Financing (2022) ](https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/proliferation-financing-australia-national-risk-assessment-2022)• [FATF NRA Guidance (2025) ](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Money-Laundering-National-Risk-Assessment-Guidance.html) Designated Services ## You are in scope if you provide a 'designated service' ### Service-Based Trigger The regime applies based on the services you provide, not your professional title or whether the work is pro bono. ### Wide Professional Capture This captures partners and directors, outsourced or virtual CFOs, registered Tax and BAS agents, trust and company service providers and bookkeepers. ### Service Mapping Required The first critical step is to conduct a detailed mapping of your service offerings against the nine designated services to determine your regulatory status. ## The Nine Designated Services at a Glance Accountants providing any of these services become reporting entities under the AML/CTF Act. ### Real property transactions Assisting in the sale, purchase, or transfer of real estate. ### Sale/transfer of companies Assisting in the sale, purchase, or transfer of a company or legal arrangement. ### Managing client property Holding, controlling, or managing client money, accounts, or assets for a transaction. ### Equity or debt financing Assisting in organising or executing financing transactions. ### Creating or restructuring companies Assisting in the creation or restructure of companies or legal arrangements (e.g., trusts, new entities). ### Selling shelf companies Selling pre-formed companies or 'shelf' entities to clients. ### Providing a director/secretary Acting as (or arranging for someone to act as) a director, secretary, or partner. ### Providing a registered office Providing a registered office or principal place of business address. ### Providing nominee shareholders Providing nominee shareholders for companies. ### When Normal Work Crosses the Line: - • A bookkeeper who establishes entities for a client or acts as a nominee director. - • A tax agent who designs and executes a group restructure, not just advises on it. - • A virtual CFO who negotiates a business sale and manages client funds for the deal. ## Who May Be Captured? The key trigger is designated services. If you are unsure whether you are covered, please take advice. Even if you are not covered, you may consider implementing guardrails. All firm sizes From sole practitioners to large practices Registered tax agents Providing designated services beyond standard tax work Corporate service arms Company formation and ASIC agency services External CFOs Outsourced financial management services Trust service providers Establishment and administration of trusts Whether you are captured depends on the designated services you provide. If unsure whether you're covered, please seek legal advice. Even if you are not covered, you may consider implementing guardrails to ensure you don't accidentally cross lines. ## Many traditional accounting services remain outside scope The following activities are generally not designated services, provided they are not part of a broader in-scope service: ### Standard Tax Compliance Preparing and lodging tax returns, BAS and IAS where no designated service is involved. ### Standalone Advisory Work Providing general accounting, tax or financial advice that is not connected to progressing a designated service. Note: if advice assists or is part of a designated service transaction, obligations may still apply. ### Audit and Assurance Conducting audits, reviews and assurance engagements in accordance with professional standards. ### Bookkeeping Services Day-to-day bookkeeping and financial record maintenance, provided the accountant is not also establishing entities or acting in nominee roles. ### Superannuation Advice Advising on superannuation contributions and strategies without managing or controlling client funds. ### Financial Reporting Preparing financial statements and management reports without involvement in underlying transactions. ## Once you are a reporting entity, you have six fundamental compliance obligations ### 1. Enrol with AUSTRAC Formally register your practice as a reporting entity. ### 2. Develop & Maintain an AML/CTF Program Create a written, risk-based program tailored to your firm's specific ML/TF risks. This is the cornerstone of your compliance. ### 3. Conduct Customer Due Diligence (CDD) Identify and verify your clients and their beneficial owners before providing a designated service, and monitor them on an ongoing basis. ### 4. Report to AUSTRAC Submit Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs) as required. ### 5. Keep Records Maintain all relevant records of CDD, transactions and your AML/CTF program for prescribed periods. ### 6. Appoint an AML/CTF Compliance Officer Designate a senior individual responsible for the oversight of your program. ## Key AML/CTF Areas for Accounting Professionals Under Tranche 2, accounting professionals face new obligations when providing designated services. Our documentation helps you navigate these requirements with confidence, covering all critical compliance areas specific to accounting service delivery. ### Company Formation & Restructuring Procedures for AML/CTF compliance when forming companies, trusts or restructuring entities for clients. ### Trust Administration AML/CTF controls for trust establishment and ongoing administration, including trustee services. ### Client Identity Verification Initial and ongoing customer due diligence (CDD), including electronic verification methods and document requirements. ### Registered Office Services Compliance requirements when providing registered office or principal place of business addresses. ### Beneficial Ownership Records Requirements for identifying and verifying beneficial owners of entities you service. ### Suspicious Matter Reporting Workflows for identifying, escalating and reporting suspicious matters to AUSTRAC. ### Compliance Officer Duties Appointment requirements, role description and ongoing responsibilities for AML/CTF compliance. ## Building an AML Program Building an AML/CTF program for an accounting practice requires multiple steps. - AML/CTF program framework for accounting practices - Risk assessment worksheet (ML/TF/PF risks) - Client identification and verification procedures - Company formation compliance workflows - Trust establishment and administration controls - Suspicious matter reporting procedures - Staff Training Register for tracking completion - Compliance officer role description ![Professionals reviewing AML compliance documentation](/assets/legal-consultation-SdDZg_6z.jpg) ## Ready to Get Started? We can help you get a headstart on your AML/CTF program. Sector-specific program documents, no subscription. Portal included (subject to licence terms). ### A HeadStart on Compliance Sector-specific compliance documents to help you build your AML/CTF program. ### Ready-to-Customise Resources Lawyer-ready to review for your business. ### Training & Record-Keeping Staff Training Register, Compliance Officer appointment documents and portal-based training record-keeping. [Get Started - Accounting Sector Edition](/programs/accounting-aml-program) From $249 inc GST · or bring your own program HeadStart Docs™ products are developed with reference to publicly available regulatory guidance. This is general information only and does not constitute legal or professional advice. You should seek advice specific to your circumstances before making compliance decisions. ## Free Resources [ ### Accounting Sector Industry Report Free Tranche 2 Accounting Sector Report. What the industry needs to know. ](/reports/accounting-professionals)[ ### AUSTRAC Starter Kits When will they be out and what to expect. ](/tranche-2-resources/austrac-starter-kit-accountants)[ ### Tranche 2 Guide Guide to the AML/CTF Amendments and Tranche 2. ](/tranche-2) ### Related Podcast Episode AML for Accounting Professionals • 16:58 Share: [](https://www.linkedin.com/sharing/share-offsite/?url=https%3A%2F%2Fopen.spotify.com%2Fepisode%2F6S3reJ8n8vKm8R7dLL2MWO)[](https://twitter.com/intent/tweet?text=AML%20for%20Accounting%20Professionals&url=https%3A%2F%2Fopen.spotify.com%2Fepisode%2F6S3reJ8n8vKm8R7dLL2MWO)[]() ### Episode Notes [From $249 ](/programs/accounting-aml-program) ### AML/CTF Compliance by Specialisation [Bookkeepers](/accounting/bookkeepers)[BAS Agents](/accounting/bas-agents)[Tax Agents](/accounting/tax-agents)[Forensic Accountants](/accounting/forensic-accountants) Related Sectors: [Business Brokers](/business-brokers)[TCSP](/tcsp)[Law Practice](/law-practice)[Insolvency Practitioners](/insolvency-practitioners) ### Learn More About Accounting Compliance [ Getting Started AUSTRAC Starter Kit for Accountants ](/tranche-2-resources/austrac-starter-kit-accountants)[ Business Budgeting for AML/CTF Compliance ](/tranche-2-resources/budgeting-amlctf-compliance)[ Accounting Accepting Crypto Deposits ](/tranche-2-resources/accepting-crypto-deposits)[ Due Diligence Third-Party Reliance for KYC ](/tranche-2-resources/third-party-reliance-kyc) ### Free Tools for Accountants [Implementation Timeline Key dates and milestones for Tranche 2 compliance ](/timeline)[Readiness Test Assess your compliance readiness in 2 minutes ](/risk-calculator)[Sanctions Screening Search Australian sanctions lists and country risk ](/sanctions-search) ### Related Resources [Accounting Professionals Report](/reports/accounting-professionals) ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) [![HeadStart Counsel](/assets/headstart-counsel-logo-dark-DW8mV5rY.png)](https://www.headstartcounsel.com.au/)[![HeadStart Search](/assets/headstart-search-logo-dark-C68UhGXl.png)](/sanctions-search)![HeadStart Verify](/assets/headstart-verify-dark-Dtad3197.png) ### Sectors [Accounting](/accounting)[Business Brokers](/business-brokers)[Buyers Agent](/programs/buyers-agent-aml-program)[Conveyancing](/conveyancing)[Insolvency](/insolvency-practitioners)[Legal](/law-practice)[Nominee Director](/programs/nominee-director-aml-program)[Precious Metals, Stones & Products](/precious-metals)[Property Development](/property-developers)[Real Estate](/real-estate)[TCSPs](/tcsp)[Virtual Address](/virtual-address) ### Resources [Free Resources](/tranche-2-resources)[Decision Trees](/decision-trees)[Tranche 2 Guide](/tranche-2)[Podcast](/podcast)[Free Sector Reports](/sector-reports)[Implementation Timeline](/timeline)[Sanctions Search](/sanctions-search)[AUSTRAC Starter Kits](/tranche-2-resources/austrac-starter-program-kits)[Budgeting for Compliance](/tranche-2-resources/budgeting-amlctf-compliance) ### Programs [Portal + AML Programs](/programs)[Pricing](/pricing)[White Label](/white-label)[External CRMs](/integrations)[AML Portal](/aml-landing)[Plug & Play Technology](/plug-and-play)[Lawyer in the Loop](/features/lawyer-in-the-loop) ### Legal [Terms & Conditions](/terms)[Privacy](/privacy) ### Connect [Programs](/programs)[Podcast](/podcast)[Feedback](/report-problem)[Our Mission](/our-mission)[Partnerships](/partnerships) ### Events [AML Conference 2026](/conference) Powered by Stripe SSL Secured 2026 Ready © HeadStart Docs Pty Ltd (ABN 12 691 347 823). 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