⚡ AUSTRAC TRANCHE 2 · ACCOUNTING · LIVE 1 JULY 2026

AML CTF compliance for Australian accountants & tax agents

From 1 July 2026, you're an AUSTRAC reporting entity — your AML/CTF program needs to be in place by 30 June 2026, the day before. We turn AUSTRAC's accountant starter kit into 4 AI workflows in 14 days. Fixed at $4,500. We implement — we don't advise.

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Built on AML/CTF Act 2006 (amended 2024) Australian-built · Sydney-based Australian-hosted data
AML CTF accountants Australia — AUSTRAC Tranche 2 implementation
Active enforcement begins 1 July 2026

If your practice helps clients form companies, manages trust money, advises on restructures, acts as a registered office, or takes on real estate work — you almost certainly provide what AUSTRAC calls a designated service. From 1 July 2026, that makes you a reporting entity under the AML/CTF Act 2006 (as amended in December 2024).

You don't need a compliance platform. You need an implementation partner who understands designated services, integrates with practice management software you already pay for, and gets you operational before the deadline. AUSTRAC publishes a free accounting program starter kit for small practices. Customising it, integrating it, training your team and standing up the registers is where the partner-time goes — that's what we do.

This page is information, not legal or tax advice. The s.32 independent review of your program must be done by a qualified independent reviewer who is not Square AI.

60-second self-check

Are you in scope for AUSTRAC Tranche 2?

Four yes/no questions. If any answer is yes, you likely provide a designated service and need an AML/CTF program before 1 July 2026.

Do you provide company or trust formation services (including restructures)?
Do you act as a registered office, virtual office, or company secretary for clients?
Do you receive, hold, control or disburse client money, accounts, or assets (trust accounts)?
Do you assist with equity/debt financing, real estate transactions, or services to high-net-worth clients with complex structures?

AUSTRAC also publishes an official reporting-entity assessment tool at austrac.gov.au — useful as a second check on the full Table 6 list.

The accounting profession at a glance

Tranche 2 lands on a profession of ~37,000 practices

According to IBISWorld (2025), Australia has roughly 36,700 accounting services businesses. Most are small practices with fewer than 15 personnel — the exact group AUSTRAC's starter kit is designed for. Peak bodies have published guidance, but the operational lift is on each practice.

CPA Australia

~173,000 members worldwide, with active Tranche 2 guidance and webinars for public-practice members.

CA ANZ

Over 120,000 members across Australia, NZ and overseas. Maintains a project plan and AML reforms micro-course.

IPA

~49,000 members. Acknowledged in AUSTRAC's starter kit suitability criteria for accounting practices.

The Tax Institute

~11,000 members. Tax-agent specific work usually isn't a designated service on its own — see FAQ.

AUSTRAC's CEO has been blunt about why the profession is in scope: accountants handle large volumes of physical currency, facilitate international transactions, and create complex legal structures that can obscure the origins of illicit funds. AUSTRAC estimates financial crime costs Australia up to $82 billion a year.

Through the accountant lens

The 6 AUSTRAC obligations you must meet

Every reporting entity has the same obligation buckets. Here's how each lands on a public-practice accounting firm.

01

Enrol with AUSTRAC

Enrolment opens 31 March 2026. If you're providing designated services on 1 July 2026, you have until 29 July 2026 to enrol. After that it's 28 days from first providing the service. Designated services for accountants include company/trust formation, registered office, managing client money, and assisting with real estate or equity/debt financing.

AML/CTF Act 2006, s.51B
02

AML/CTF program

A documented program covering your risk assessment, customer due diligence, ongoing monitoring, suspicious matter reporting, training, governance and an independent evaluation at least every 3 years. Newly regulated firms get an extended deadline for their first independent review, set by AUSTRAC based on your account number. The program must be approved by senior management (a sole practitioner can self-approve). The s.32 independent review cannot be done by us.

AML/CTF Act 2006, s.81-84 & s.32
03

Customer due diligence (CDD)

Verify client identity before providing a designated service. Identify beneficial owners of body corporates and beneficiaries of trusts. Apply enhanced CDD for PEPs and high-risk clients with senior-management sign-off. Apply simplified CDD for low-risk clients with documented justification. Ongoing monitoring throughout the relationship.

AML/CTF Act 2006, s.32-36
04

Suspicious Matter Reports (SMR)

If you suspect on reasonable grounds that a matter relates to money laundering, terrorism financing or a serious offence, you must submit a SMR through AUSTRAC Online. Disclosing that a SMR has been (or will be) lodged is the tipping-off offence — 5 years imprisonment. AI can draft the SMR; only the partner submits.

AML/CTF Act 2006, s.41 & s.123
05

Records retention

Keep records of customer identification, transactions, AML/CTF compliance activities, training and risk reviews for at least 7 years. Cash transactions of AUD $10,000 or more must be reported as Threshold Transaction Reports (TTRs) — separate from SMRs.

AML/CTF Act 2006, s.107-116
06

Annual compliance report

Each financial year you submit a compliance report to AUSTRAC summarising how you've met your AML/CTF obligations — program status, training completed, CDD activity, SMRs lodged. The first report covers the partial period from when you commence designated services through to the end of the reporting year. Our Sprint sets up the evidence pack so the report writes itself.

AML/CTF Act 2006 — annual compliance reporting

What enforcement looks like

Civil penalty up to ~$33M corporate / ~$6.6M individual per contravention (penalty unit $330 in 2026). AUSTRAC publishes enforcement actions, which carries downstream consequences with CPA Australia, CA ANZ or IPA on top of the AUSTRAC penalty. Money laundering is up to 25 years under Criminal Code s.400. Operating a designated service from 1 July 2026 without enrolment, an AML/CTF program and a CDD process is a contravention of the Act — civil penalty and potential criminal exposure.

Three real risk scenarios

What ML/TF risk looks like in practice

Illustrative scenarios drawn from AUSTRAC's typology guidance for accountants. The AI flags. The accountant decides.

1. Client requests offshore trust for "asset protection"

TriggerNew client wants a multi-layered offshore trust structure citing "asset protection" — but operating purpose is vague, source of wealth is unclear, and they push back on standard CDD.
What the AI flagsBeneficial-ownership chain crosses 3+ jurisdictions; PEP screen pings on a related party; structure has no obvious commercial substance.
What you decideWhether to apply enhanced CDD, decline the engagement, or lodge a SMR. The AI never decides — and never tips off the client about a SMR.

2. Cash-heavy client with inconsistent declarations

TriggerLong-standing small-business client suddenly has cash deposits well beyond declared turnover; structuring under the $10,000 reporting threshold; reluctant to explain source.
What the AI flagsPattern of sub-threshold deposits; declared income vs. observed banking activity gap; possible structuring indicators.
What you decideUpdate CDD, request source-of-funds documentation, escalate to AMLCO, and consider a SMR. Threshold Transaction Reports for any single $10K+ cash event.

3. Registered office service with vague purpose

TriggerProspect wants a registered office address for a newly incorporated Pty Ltd. No operating premises, no website, no clear business purpose — and the directors are nominee.
What the AI flagsRegistered office is a designated service in its own right; nominee director pattern; absence of commercial substance suggests potential shell-company use.
What you decideApply enhanced CDD, demand identification of true controlling person, and decline if you can't satisfy yourself on source of funds and purpose.
The product

4 AI workflows, customised for accountants

Built on the AUSTRAC accounting starter kit, integrated with the practice software you already use. You keep the IP. No platform lock-in.

1. CDD Intake Agent

A smart onboarding agent that runs corporate, trust and individual CDD without your team retyping anything.

  • ABN/ACN lookup with ASIC integration; auto-populates entity records
  • Beneficial-ownership mapping for body corporates and trusts (named clients + ultimate controllers)
  • Source-of-funds and source-of-wealth prompts triggered by risk score
  • PEP and sanctions screening with audit trail
  • Pre-commencement client refresh workflow under s.36
Saves 30-45 min per new client onboarding

2. Training Register Automation

A tiered training register so partners, accountants, BAS-handling admins and reception each see the right module — and nothing they don't need.

  • Role-based modules: admin / accountant / partner / AMLCO
  • Auto-renewal reminders; completion tracking; staff attestations
  • CPD-compatible logging where your professional body recognises it
  • AUSTRAC-ready evidence pack export for any regulator request
  • 7-year retention with timestamped audit trail
Eliminates ~80 partner hours/year of register admin

3. SMR Draft Assist

Drafts a Suspicious Matter Report in AUSTRAC's expected format from staff notes. The lawyer or AMLCO reviews and submits — the AI never submits.

  • Accountant-specific templates: structuring, suspicious restructures, shell-company indicators, third-party payers
  • Pre-fills the AUSTRAC Online SMR fields from your file notes
  • Tipping-off awareness built into the workflow (s.123 reminders)
  • Drafts disengagement letter where the matter requires it
10-min draft vs. 90-min cold start

4. Ongoing Monitoring & Alerts

Light-touch monitoring across the client lifecycle — not a transaction-monitoring platform, just the right reminders at the right time.

  • Annual client-risk review reminders, weighted by risk tier
  • Beneficial-ownership change checks (ASIC pulses for corporate clients)
  • PEP and sanctions re-screening on a defined cadence
  • Quarterly AMLCO dashboard summarising open items
Replaces a quarterly half-day partner review
Live interactive demo

See how the workflows actually run

Walk through the AI agents the way your practice would — onboarding a corporate client, logging a partner training session, drafting an SMR from file notes, and triggering a beneficial ownership refresh. No signup. No sales call. Roughly 5 minutes end to end.

Watch the live demo
~5 minutes No signup required Real workflows, sample data
CDD Intake
Onboard a corporate client
Training Register
Log a partner session
SMR Draft Assist
Draft from file notes
Monitoring
Beneficial ownership refresh
Fixed price · 14-day delivery

No platform fees. No lock-in.

One up-front engagement to get you compliant by 1 July 2026. An optional retainer if you'd rather not run it in-house.

Optional Monthly Retainer

$300 per month · cancel anytime
  • Ongoing monitoring & alerts oversight
  • Register updates and quarterly review reminders
  • Two additional training micro-modules per year
  • SMR Draft Assist priority support
  • Software updates as AUSTRAC guidance evolves
Add to my Sprint
Founder pricing — first 100 firms only, locked for 12 months. Engagement slots fill ~2 weeks ahead, so book the readiness call to confirm availability for your timeline.
Sole practitioner? Read this first. The Sprint is built for practices of 3+ personnel where the saved partner time and tiered training justify the engagement. If you're a solo practitioner with a low-risk client base, the AUSTRAC starter kit plus a $1,200/yr compliance tool (TrustEasy and similar) may be enough on its own. Book the readiness call anyway — if that's the right answer for you, we'll say so. The s.32 independent review is conducted by a qualified independent reviewer — not Square AI, regardless of which path you choose.
14-day delivery

From signed engagement to live program

Two weeks of focused work, around your existing client load. No big consulting engagement.

W1

Practice review & program customisation

Day 1-7. We map your designated services, walk through the starter kit, customise risk assessment and policy templates, and identify integration points with your practice software.

W2

AI workflow build & integration

Day 8-13. We stand up the 4 AI workflows, integrate with Xero PM, MYOB, Karbon, FYI Docs or whichever stack you run, and load your AMLCO dashboard.

D14

Staff training & go-live

Day 14. Tiered 60-minute training (admin / accountants / partners), evidence pack handover, and your AML/CTF program goes live. You're operational well ahead of 1 July 2026.

Why us for accountants

Honest comparison on a single page

The path that's actually right for a small-to-mid practice depends on your size and risk profile. Here's how the four most common options compare.

 
DIY (starter kit alone)
Software platforms (InfoTrack, TrustEasy)
Generic AI agency
Square AI
Cost
Free + 60-100 partner hrs
Free–$3,600/yr ongoing
$5K-$15K (variable)
$4,500 fixed
Time to compliant
3-6 months
Tool live in days, your program still DIY
4-8 weeks
14 days
Knows designated services
You learn it
Tools, not advice
No
Yes
Customised AML/CTF program
You write it
Templates only
Generic
Built from your designated services
Integrates with practice software
Manual
Limited (mostly own platform)
Sometimes
Xero, MYOB, Karbon, FYI, BGL, Class
AI workflows included
None
Workflow chassis only
Generic
4, accountant-specific
You keep the IP
Yes
Subscription / lock-in
Sometimes
Yes
Independent reviewer (s.32)
You arrange
You arrange
You arrange
You arrange — clean separation

Software platforms and the Sprint aren't either/or. Many of our clients use a tool like TrustEasy or InfoTrack for ongoing register admin after we've built and customised the program. We build the foundation; the tool runs the day-to-day.

FAQ

Common questions from accounting partners

Why pay for the Sprint when InfoTrack's Compliance Centre is free?

InfoTrack and similar platforms (TrustEasy, AMLTranche) are tools — they give you registers, ID checks and a workflow chassis. They don't customise your AML/CTF program from scratch, map your designated services, or train your staff to operate it. The Sprint is implementation: we build your program on the AUSTRAC starter kit, configure the AI workflows, integrate with your practice software, and hand over the IP. Many of our clients keep using a software platform for ongoing register administration after we've built the foundation. The tool and the implementation aren't competing — they're sequential.

I'm a sole practitioner — is the Sprint right for me?

Often, no. The Sprint is built for practices of 3+ personnel where saved partner time and tiered training justify the $4,500. If you're solo with a low-risk client base, the AUSTRAC starter kit plus a $1,200/yr compliance tool may serve you better than us. Book the readiness call anyway — we'll tell you straight, including "you don't need us" if that's the honest answer. We'd rather lose 15 minutes than mis-sell you a Sprint you can't justify.

Do bookkeepers need AML/CTF training?

Bookkeeping on its own usually isn't a designated service. But if a bookkeeper works in a practice that does provide designated services (trust account work, company formation), they need role-appropriate training under your AML/CTF program. Our training register tiers cover this exactly — admin/bookkeeper modules are lighter than the partner-level ones.

What about BAS agents?

Pure BAS preparation is typically outside the AUSTRAC designated services list. The trigger is what the practice does around BAS work — managing client funds, helping with restructures, advising on offshore arrangements. If you're a BAS agent who only prepares activity statements and lodges, you're likely not in scope. If you're unsure, run our 60-second self-check or get advice from your professional body.

What's a "designated service" for an accountant?

The full list is in Table 6 of the AML/CTF Act. The ones most accountants actually provide are: assisting with real estate transactions; creating or restructuring companies, trusts and other legal arrangements; receiving, holding, controlling or managing client money or property; assisting with equity or debt financing; providing a registered office or business address; and acting as or arranging nominee directors or trustees. Provide one and you're a reporting entity.

Can I use my existing practice management software?

Yes — that's the whole point. Our Sprint integrates with Xero Practice Manager, MYOB Practice, Karbon, FYI Docs, ATOmate, Class Super, BGL CAS 360 and similar tools. We don't replace anything you already pay for. The AML workflows sit alongside your existing client onboarding and document workflows.

Do I need a separate AML/CTF Compliance Officer?

You need an AMLCO appointed under your program. In a small practice, that's usually a partner with delegated responsibility — same person can also cover senior management approval. Larger practices may want a dedicated AMLCO. We help you document the role and the personnel due diligence under the Rules.

How does this work with my professional body's ethical standards?

AML/CTF compliance is complementary to APES 110 and your professional body's ethical standards — not a replacement. Where there's overlap (client identification, integrity, due care), we map your existing professional obligations into the AML/CTF program rather than duplicating them. CPA Australia, CA ANZ and IPA all publish Tranche 2 guidance and we align our customisation to it.

What about clients I've had for 20 years?

The Act has pre-commencement customer rules in s.36. You generally don't need to redo full CDD on long-standing clients on day one — but you do need to apply CDD if anything triggers a SMR, if their risk profile materially changes, or when a new designated service starts. Our CDD Intake Agent has a pre-commencement refresh workflow that prioritises higher-risk legacy clients first.

What about audit clients vs. accounting clients?

Audit work on its own is generally not a designated service. But if your firm provides audit alongside designated services for the same client (or another arm of the same group), the audit client may still come into scope through other services they receive. Map the services, not the client. We do this mapping in Week 1 of the Sprint.

Book your readiness call

Get an honest 15-minute scope of where you stand

No sales pitch. We'll tell you whether the Sprint is right for your practice or whether you genuinely just need the starter kit. Sydney-based. We respond same business day.

Response time

Same business day, Mon-Fri

Location

Penrith NSW · Servicing all of Australia

Tell us about your practice

14-day delivery means we can take a small number of new firms each fortnight. Get on the list.

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⚡ 1 JULY 2026 IS LOCKED

Don't be the practice that missed the deadline.

14 days. $4,500 fixed. Customised starter kit + 4 AI workflows + staff training. You keep the IP.

Real estate firm? See our real estate page. Lawyer or conveyancer? See our legal page.