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.
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.
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.
AUSTRAC also publishes an official reporting-entity assessment tool at austrac.gov.au — useful as a second check on the full Table 6 list.
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.
~173,000 members worldwide, with active Tranche 2 guidance and webinars for public-practice members.
Over 120,000 members across Australia, NZ and overseas. Maintains a project plan and AML reforms micro-course.
~49,000 members. Acknowledged in AUSTRAC's starter kit suitability criteria for accounting practices.
~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.
Every reporting entity has the same obligation buckets. Here's how each lands on a public-practice accounting firm.
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.
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.
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.
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.
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.
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.
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.
Illustrative scenarios drawn from AUSTRAC's typology guidance for accountants. The AI flags. The accountant decides.
Built on the AUSTRAC accounting starter kit, integrated with the practice software you already use. You keep the IP. No platform lock-in.
A smart onboarding agent that runs corporate, trust and individual CDD without your team retyping anything.
A tiered training register so partners, accountants, BAS-handling admins and reception each see the right module — and nothing they don't need.
Drafts a Suspicious Matter Report in AUSTRAC's expected format from staff notes. The lawyer or AMLCO reviews and submits — the AI never submits.
Light-touch monitoring across the client lifecycle — not a transaction-monitoring platform, just the right reminders at the right time.
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 demoOne up-front engagement to get you compliant by 1 July 2026. An optional retainer if you'd rather not run it in-house.
Two weeks of focused work, around your existing client load. No big consulting engagement.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Same business day, Mon-Fri
Penrith NSW · Servicing all of Australia
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.