Table 6: The 9 Services That Make Lawyers, Accountants & Conveyancers Reporting Entities
A line‑by‑line breakdown of every designated service in Table 6 — what triggers it, what doesn't, the exclusions that carve things out, and how AUSTRAC interprets “assisting” in practice.
Executive Summary
Table 6 of subsection 6(5B) of the AML/CTF Act is the table that brings professional services into Australia's anti-money laundering regime. It contains 9 designated service items covering real estate transactions, business transfers, client money management, equity and debt financing, shelf companies, company and trust formation, nominee arrangements, and registered office addresses.
The regime regulates services, not professions. Whether you are caught depends on what you do, not what you call yourself. A financial advisor who creates a trust is caught just as much as a lawyer who does the same. A virtual office provider who offers registered office addresses is caught just as much as a TCSP.
This article breaks down each of the 9 items with real-world scenarios, the 6 exclusions that protect routine professional work, legal professional privilege protections, and a profession-by-profession guide to which items apply to you.
How Table 6 Works
The structure and the key principle
Table 6 was inserted into Section 6 of the AML/CTF Act by Schedule 3, Part 3 of the Amendment Act 2024. It sits in a new subsection 6(5B). It does not commence until 1 July 2026, but entities can enrol with AUSTRAC from 31 March 2026.
Each row in the table defines two things: the provision of a designated service (what the reporting entity does) and the customer of the designated service (who you must conduct CDD on). This matters because your AML/CTF obligations — enrolment, CDD, reporting, record-keeping — flow from providing a designated service to a customer.
The key principle: The AML/CTF regime regulates services, not professions. AUSTRAC puts it plainly: “it is what you do, not what you are, which is important.” A tax accountant who never touches trust accounts or company formations may not be caught at all. A financial advisor who creates trusts for clients is caught even though “financial advisor” is not mentioned in the legislation.
What "Assisting" Means
AUSTRAC's October 2025 guidance on the trigger word
Six of the nine Table 6 items use the word “assisting” or “acting for or on behalf of.” Understanding what AUSTRAC considers “assisting” to mean is critical to determining whether your work triggers a designated service.
In its October 2025 guidance, AUSTRAC drew a clear line:
Your actions directly advance the relevant transaction or outcome. You are acting on instructions to implement a transaction.
● Preparing a contract for sale of real estate
● Conducting title searches
● Drafting a trust deed to establish a trust
● Holding funds in trust for settlement
You are merely influencing how the customer proceeds, providing general advice, or offering ancillary services.
● Discussing pros and cons of buying property
● Advising on the legal effect of contract terms
● Providing a simple referral to another professional
● Preparing financial statements the client might use later
AUSTRAC also clarified when the designated service commences. It starts when you act on instructions in relation to a relevant transaction — typically when two or more parties to a transaction exist, or when preparatory steps are taken to create or restructure a body corporate or legal arrangement.
Practical implication: The “assisting” threshold protects general advisory work. If your practice is purely advisory — telling clients what the law says, explaining options, providing opinions — without acting on instructions to execute a transaction, you may not be providing a designated service. But the moment you start drafting documents, lodging forms, or holding funds to implement a transaction, you cross the line.
AUSTRAC has also confirmed that legal dispute resolution services will generally not fall within Table 6. Litigation typically relates to determining legal questions on matters that have already occurred, not matters that are in progress or will occur in the future. However, if a dispute results in a transaction (e.g., a settlement that involves the transfer of property), the work to implement that settlement may itself be a designated service.
The 9 Designated Service Items
Click any row in the table or any card below for full breakdown, scenarios, and key insights
| Item | Designated Service |
|---|---|
| 1 | Sale, Purchase or Transfer of Real Estate The person being assisted |
| 2 | Sale, Purchase or Transfer of a Body Corporate or Legal Arrangement The person being assisted |
| 3 | Managing Client Money, Accounts, Securities or Property The person whose money/property is being managed |
| 4 | Equity or Debt Financing The person being assisted |
| 5 | Selling or Transferring a Shelf Company The buyer or transferee |
| 6 | Creation or Restructuring of a Body Corporate or Legal Arrangement The person being assisted, plus: (a) if creating a company — the beneficial owners and directors; (b) if creating an express trust — the trustee, settlor, and beneficiaries |
| 7 | Acting as a Director, Secretary, Partner, Trustee or Power of Attorney The nominator (the person on whose behalf you act) |
| 8 | Acting as a Nominee Shareholder The nominator |
| 9 | Providing a Registered Office or Business Address The person to whom the service is provided |
The Item 3 Exclusions
Subsection 5C — when holding client money is NOT a designated service
Item 3 (managing client money and property) is the item most likely to accidentally catch businesses that are not engaged in transactional work. To prevent this, the Amendment Act includes six specific exclusions in subsection 5C. If your situation falls within any of these, Item 3 does not apply.
Why this matters: Without subsection 5C, every lawyer who receives a retainer payment or every property manager who collects rent would be providing a designated service. The exclusions ensure that only the genuine ML/TF risk activity — holding someone else's money as part of facilitating a transaction — is captured.
Legal Professional Privilege
Schedule 4 — the compromise that ended the 20-year standoff
For two decades, the legal profession successfully argued against being included in Australia's AML/CTF regime. The primary objection was that AML/CTF obligations would undermine legal professional privilege (LPP) — the fundamental right of clients to communicate with their lawyers in confidence.
Schedule 4 of the Amendment Act resolves this by preserving LPP while still requiring lawyers to participate in the regime. Here are the key provisions:
Bottom line for lawyers: LPP is intact. You can still refuse to disclose privileged information. But you cannot use LPP as a blanket excuse to avoid all AML/CTF obligations. If you provide designated services, you must enrol, conduct CDD, have a program, and report suspicious matters — filing an LPP Form where necessary to protect privileged information within those processes.
Which Items Apply to You?
Scenarios by profession
The scenarios below are based on the Amendment Act and AUSTRAC's October 2025 guidance. They are indicative, not exhaustive — your specific circumstances determine whether a designated service is triggered.
Conveyancer / Settlement Agent
Lawyer (Property / Commercial)
Accountant
Trust & Company Service Provider (TCSP)
Don't Forget Table 5
Real estate agents have their own table
While Table 6 covers professional services, real estate agents and property developers are primarily covered by Table 5 (subsection 6(5A)), which has just two items:
| Item | Designated Service | Customer |
|---|---|---|
| 1 | Brokering the sale, purchase or transfer of real estate on behalf of a buyer, seller, transferee or transferor in the course of carrying on a business | Both the seller/transferor and the buyer/transferee |
| 2 | Selling or transferring real estate in the course of carrying on a business selling real estate, where the sale or transfer is not brokered by an independent real estate agent | The buyer or transferee |
Table 5 Item 1 covers traditional real estate agents and buyers' agents who broker transactions. Table 5 Item 2 covers property developers and other businesses that sell real estate directly without using an independent agent. Together with Table 6 Items 1 and 3, this creates a comprehensive net around property transactions — the agent, the professional advisor, and anyone holding funds are all covered.
Related Articles
Continue reading
References & Further Reading
Primary sources used in this article
Primary Sources
- Federal Register of Legislation — AML/CTF Amendment Act 2024 — Schedule 3 (Regulating Additional High-Risk Services) Link
- Federal Register of Legislation — AML/CTF Rules 2025 — Part 5 (AML/CTF Programs) and Part 6 (CDD) Link
- AUSTRAC — Professional Services (Reform) — Table 6 Guidance (October 2025) Link
- AUSTRAC — Legal Professional Privilege (Reform) Guidance Link
- AUSTRAC — Legal Profession Program Starter Kit Link
- Department of Home Affairs — Regulating Additional High-Risk Services — Overview Link
- Parliament of Australia — AML/CTF Amendment Bill 2024 — Explanatory Memorandum Link
Preparing for Tranche 2?
lex-aml maps every Table 6 item to CDD workflows, risk assessments, and reporting templates — so you know exactly what to do for each designated service you provide.
Request Early AccessDisclaimer: This article is published by GetPost Labs Pty Ltd, a technology company building compliance software. All content is for educational purposes only and does not constitute legal, financial, or compliance advice. While we make every effort to ensure accuracy, this article may contain errors or omissions. Always refer to the authoritative text on legislation.gov.au and seek professional advice for your specific circumstances. If you spot an error or have a suggestion, please reach out to sumit@getpostlabs.io.