Table 6: the nine designated services that make a professional a reporting entity
Whether you are caught by Australia’s AML/CTF regime depends on the services you provide, not on your profession. Table 6 is the list. Here is every item verbatim, who its customer is, what it excludes, and what AUSTRAC says the word “assisting” means.
Educational purposes only This page is general education about Australian law, published by a technology company. It is not legal advice and does not tell you whether your business is a reporting entity. Read the provisions on the Register and take advice on your own circumstances.
The short answer
Nine services, one table, in section 6 of the Act
Table 6 sits in subsection 6(5B) of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). It was inserted by the Amendment Act 2024 and has applied since 1 July 2026. Provide any one of its nine services in the course of carrying on a business and you provide a designated service — which is what makes a business a reporting entity, with obligations to enrol, hold an AML/CTF program, do customer due diligence, report and keep records.
The regime regulates services, not professions. A financial adviser who takes instructions and creates a trust is caught; a tax accountant who never touches a transaction, a structure or client money may not be caught at all. Two people with the same qualification can land on opposite sides of this table.
The nine designated services in Table 6 of subsection 6(5B) of the AML/CTF Act 2006, with the customer of each service
the person and: (a) if the body corporate is a company and the service is creating the company—the beneficial owners and directors of the company; or (b) if the legal arrangement is an express trust and the service is creating the express trust—the trustee, settlor and beneficiaries of the trust
Real estate agents and property developers are not in this table — they are in Table 5. Bullion dealers, jewellers and other dealers in precious metals, stones and products are not here either — they are in Table 2, which works on entirely different tests.
Nine doorways, and you only need to be through one of them
What follows from providing one
Table 6 is a threshold, not an obligation. Cross it once and the Act’s general machinery applies to you: enrolment with AUSTRAC, an AML/CTF program with a risk assessment and policies, customer due diligence before you provide the service, ongoing monitoring, reporting where a suspicion is formed, and records kept for seven years. None of that is in Table 6 itself — the table only decides whether the rest of the Act is speaking to you. Table 6 arrived with the Tranche 2 reforms, which commence on 1 July 2026.
Item by item
Each service, in the Act’s own words
The quoted provision under each heading is the Act, word for word. The examples beneath it are AUSTRAC’s published guidance, or our reading of it — guidance explains the law, it does not make it, and where the two differ the Act controls.
Item 1Real estate transactions
Transactions to sell, buy or transfer real estate
THE ACT — s 6(5B) TABLE 6, ITEM 1
“assisting a person in the planning or execution of a transaction, or otherwise acting for or on behalf of a person in a transaction, to sell, buy or otherwise transfer real estate, where: (a) the service is provided in the course of carrying on a business; and (b) the sale, purchase or other transfer is not pursuant to, or resulting from, an order of a court or tribunal”
Customer of the designated service: “the person”
This is the service
Preparing a contract for the sale of real estate once buyer and seller have agreed the price
Acting for the buyer or the seller to plan or execute the transfer
Conveyancing work done to give effect to a binding financial agreement between separating parties
This is not
Advising the conveyancer on the legal effect of terms in a contract for sale — that influences the transaction without directly advancing it
Acting on a transfer made pursuant to, or resulting from, a court or tribunal order
Advising on rights over a property where the only transaction — the original purchase — is already complete
Typically provided byConveyancers · Property lawyers · Settlement agents · Accountants acting in a property transaction
This is the one Table 6 item the AML/CTF Rules address specifically: the delayed-CDD and reliance provisions for real estate transactions reach item 1, and nothing else in Table 6.
Item 2Business and entity transfers
Transactions to sell, buy or transfer a body corporate or legal arrangement
THE ACT — s 6(5B) TABLE 6, ITEM 2
“assisting a person in the planning or execution of a transaction, or otherwise acting for or on behalf of a person in a transaction, to sell, buy or otherwise transfer a body corporate or legal arrangement, where: (a) the service is provided in the course of carrying on a business; and (b) the sale, purchase or other transfer is not pursuant to, or resulting from, an order of a court or tribunal”
Customer of the designated service: “the person”
This is the service
Representing the client in negotiations for the sale of a company
Preparing or reviewing the contract of sale, conducting due diligence, valuing assets and liabilities in anticipation of the sale
Obtaining FIRB approvals or ASIC waivers for the client, and preparing the transfer documents lodged with an authority
This is not
Tax advice on the implications of selling a body corporate, given before there is a transaction or an identified buyer
A transfer made pursuant to, or resulting from, an order of a court or tribunal
AUSTRAC’s guidance and its starter kits add that item 2 “only applies where the sale, purchase or transfer relates to a controlling interest”. That qualifier is not in the Act — see the section on the Rules below.
Item 3Client money and property
Receiving, holding, controlling or managing money or property in a transaction
THE ACT — s 6(5B) TABLE 6, ITEM 3
“receiving, holding and controlling (including disbursing) or managing a person’s: (a) money; or (b) accounts; or (c) securities and securities accounts; or (d) virtual assets; or (e) other property; as part of assisting the person in the planning or execution of a transaction, or otherwise acting for or on behalf of a person in a transaction, in the course of carrying on a business (other than in a circumstance covered by subsection (5C))”
Customer of the designated service: “the person”
This is the service
Managing sale proceeds or purchase funds for a client in escrow
Holding money or property before it is settled as trust property on the creation of an express trust
Holding authority to make payments over a client’s bank or securities account, including under a power of attorney
This is not
Taking payment for your own goods or services — your fees are excluded by paragraph 5C(a)
Operating a trust account where the business provides no other designated service and the money is for payments reasonably incidental to a non-designated service
Receiving a judgment sum into trust and paying it on, where the money is payable under a court or tribunal order
Typically provided byLawyers operating trust accounts · Conveyancers holding settlement funds · Accountants holding client funds in a transaction
Item 3 carries six exclusions in subsection 6(5C) — more than any other item — and they are what keep ordinary fee-taking and court-ordered payments out of the regime.
Item 4Equity and debt financing
Transactions for equity or debt financing of a body corporate or legal arrangement
THE ACT — s 6(5B) TABLE 6, ITEM 4
“assisting a person in organising, planning or executing a transaction, or otherwise acting for or on behalf of a person in a transaction, for equity or debt financing relating to: (a) a body corporate (or proposed body corporate); or (b) a legal arrangement (or proposed legal arrangement); in the course of carrying on a business”
Customer of the designated service: “the person”
This is the service
Preparing loan or subscription documentation for a company raising debt or equity
Acting for a client in a capital raising — preparing shareholder resolutions and investor documents
Preparatory steps that directly advance the financing, such as drafting a term sheet on instructions
This is not
General advice about financing options where nothing is being organised, planned or executed
Services that merely influence whether financing proceeds — a credit rating obtained for the company, for example
Typically provided byLawyers · Accountants · Corporate advisers
Item 4 is the one item that uses “organising” as well as “planning” — AUSTRAC treats preliminary and preparatory steps as caught where they directly advance the financing.
Item 5Shelf companies
Selling or transferring a shelf company
THE ACT — s 6(5B) TABLE 6, ITEM 5
“selling or transferring a shelf company, in the course of carrying on a business”
Customer of the designated service: “the buyer or transferee”
This is the service
Selling a pre-registered company from inventory to a client
Transferring the shares and directorship of a shelf company to a buyer
This is not
Registering a brand-new company on a client’s instructions — that is item 6, not item 5
Providing company secretarial services to a company you are not selling or transferring
Typically provided byTrust and company service providers · Corporate secretarial firms · Lawyers who maintain companies for sale
Note who the customer is: the buyer or transferee, not the person instructing you. Item 5 has no “assisting” element and no stated exception — selling or transferring is enough.
Item 6Company and trust formation
Creating or restructuring a body corporate or legal arrangement
THE ACT — s 6(5B) TABLE 6, ITEM 6
“assisting a person to plan or execute, or otherwise acting on behalf of a person in, the creation or restructuring of: (a) a body corporate (other than a corporation under the Corporations (Aboriginal and Torres Strait Islander) Act 2006); or (b) a legal arrangement; in the course of carrying on a business”
Customer of the designated service: “the person and: (a) if the body corporate is a company and the service is creating the company—the beneficial owners and directors of the company; or (b) if the legal arrangement is an express trust and the service is creating the express trust—the trustee, settlor and beneficiaries of the trust”
This is the service
Drafting a trust deed and facilitating its execution on a client’s instructions
Registering a company with ASIC on instructions
Splitting one body corporate into several, merging several into one, or converting a company limited by guarantee into one limited by shares
This is not
General advice on the benefits of a structure, and a referral to someone who will actually create it — that influences the creation without directly advancing it
Creating a corporation under the Corporations (Aboriginal and Torres Strait Islander) Act 2006, which the item excludes
Drafting a will that establishes a testamentary trust — “express trust” is defined to exclude testamentary trusts
Typically provided byLawyers · Accountants · Trust and company service providers · Insolvency practitioners
Item 6 has the widest customer definition in Table 6. Create a company and your customers include its beneficial owners and directors; create an express trust and they include the trustee, settlor and beneficiaries. That is more due diligence than any other item asks for.
Item 7Nominee office-holder roles
Acting as, or arranging, a director, secretary, partner, trustee or attorney
THE ACT — s 6(5B) TABLE 6, ITEM 7
“acting as, or arranging for another person to act as, any of the following, on behalf of a person (the nominator), in the course of carrying on a business: (a) a director or secretary of a company; (b) a power of attorney of a body corporate or legal arrangement; (c) a partner in a partnership; (d) a trustee of an express trust; (e) a position in any other legal arrangement that is functionally equivalent to a position mentioned in any of the above paragraphs; other than in a circumstance covered by subsection (5E)”
Customer of the designated service: “the nominator”
This is the service
Providing a nominee director for a client’s company
Arranging for a staff member to act as secretary of a client’s company
Acting as professional trustee of an express trust on the settlor’s instruction
This is not
Acting, or arranging for another to act, in a fiduciary capacity pursuant to or as a result of a court or tribunal order
Acting as the trustee of a regulated debtor’s estate under Schedule 2 to the Bankruptcy Act 1966
Sitting on the board of your own company — there is no nominator
Typically provided byTrust and company service providers · Professional trustee companies · Firms providing nominee directors
The test is the nominator. If someone else has put you in the seat and you hold it on their behalf, item 7 is engaged; the two exclusions in subsection 6(5E) are both court-driven appointments.
Item 8Nominee shareholders
Acting as, or arranging, a nominee shareholder
THE ACT — s 6(5B) TABLE 6, ITEM 8
“acting as, or arranging for another person to act as, a nominee shareholder of a body corporate or legal arrangement, on behalf of a person (the nominator), in the course of carrying on a business”
Customer of the designated service: “the nominator”
This is the service
Holding shares or an interest in a company on behalf of a client and voting them on the client’s instructions
Arranging for a third party to hold shares as nominee for your client
This is not
Holding shares in your own right as a genuine investor
Typically provided byTrust and company service providers · Corporate service providers · Firms holding shares for clients
The Act defines a nominee shareholder in section 5: a person who holds shares or an interest on behalf of a nominator AND either votes on the nominator’s instructions or receives dividends for them, or both.
Item 9Registered office addresses
Providing a registered office or principal place of business address
THE ACT — s 6(5B) TABLE 6, ITEM 9
“providing a registered office address or principal place of business address of a body corporate or legal arrangement, in the course of carrying on a business”
Customer of the designated service: “the person to whom the service is provided”
This is the service
Providing your firm’s address as the registered office of a client’s company
Offering a registered business address for an ASIC registration
This is not
Providing a mailing address or PO box that is not the registered office or principal place of business
Typically provided byTrust and company service providers · Virtual and serviced office providers · Firms whose address appears on a client’s ASIC record
The shortest item in Table 6 and the easiest to overlook: it is a designated service in its own right, so it triggers its own obligations even where it is bundled with company formation under item 6.
AUSTRAC guidance · not law
The whole question is what “assisting” means
Five of the nine items turn on assisting a person, or otherwise acting for or on behalf of them. AUSTRAC’s professional-services guidance sets out two principles, and between them they decide both who is regulated and from what moment.
Who
“a person whose assistance to a customer directly advances a relevant transaction or a creation or restructure of a body corporate or a legal arrangement. Merely influencing how the customer proceeds, providing general advice or ancillary services isn’t sufficient.”
When
“a person starts to provide one of the designated services when they act on instructions in relation to a relevant transaction or the creation or restructure of a body corporate or a legal arrangement. This will typically be when two or more parties to a transaction exist or when preparatory steps are taken…”
AUSTRAC, Professional services (reform) — guidance, not law
The line is drawn between advancing and influencing. AUSTRAC’s own worked example is a solicitor who advises a conveyancer on the legal effect of terms in a contract for sale: that influences the transaction, so it is not caught, while the conveyancing that transfers the property is. A financial adviser who explains the benefits of a trust and refers the client to an accountant is not providing item 6; the accountant who drafts the deed is.
Litigation mostly sits outside the table. AUSTRAC says legal dispute resolution services “will generally not fall under the scope of table 6”, because they often do not directly advance a transaction and relate to determining legal questions about matters that have already occurred. But watch what follows a dispute: if the parties settle by binding financial agreement rather than court order, the conveyancing done to give effect to it is item 1 — whereas a transfer made pursuant to a court order is excluded by the item itself.
Advising on a structure influences it. Drafting the deed advances it.
The carve-outs
Six exclusions keep item 3 from swallowing every practice
Item 3 — client money and property — is the item most likely to catch a business that does no transactional work at all, so the Act carves six circumstances out of it in subsection 6(5C). Without paragraph (a), every professional who banked a fee would be a reporting entity.
Item 3 is about holding someone else’s money in a transaction — not about being paid
(a)
The money, accounts, securities, securities accounts, virtual assets or other property being held or managed is payment by the person for the provision of goods or services by the business.
Your own fees. Taking payment for your own work is not a designated service.
(b)
Both: the business does not provide any designated services other than the services referred to in item 3; and the property being held or managed is for payments reasonably incidental to the provision by the business of a service that is not a designated service.
The Act’s own example is fees paid to a barrister for representation in legal proceedings, or property management services. Note the first limb: provide any other designated service and this exclusion is gone.
(c)
The property being held or managed is to be received or payable under an order of a court or tribunal.
A judgment sum received into a trust account and paid on to the client.
(d)
The service provided by the business is the receipt or disbursement of a payment mentioned in subsection (5D).
Payments to or from a government body, a court or tribunal, a public international organisation, or a licensed insurer (including self-insured licensees).
(e)
The service is any other designated service.
No double-counting: if the holding is already captured elsewhere, it is not also item 3.
(f)
A circumstance specified in the AML/CTF Rules.
A hook for future Rules. As at the current compilation of the Rules, nothing has been specified under it.
AML/CTF Act 2006 (Cth), s 6(5C) and s 6(5D) — condensed; read the provision in full on the Register
And two more for item 7
Subsection 6(5E) takes court-driven appointments out of the nominee office-holder item. Being made an administrator, liquidator or trustee in bankruptcy by a court is not the risk item 7 is aimed at:
acting, or arranging for another person to act, in a fiduciary capacity pursuant to, or as a result of, an order of a court or a tribunal
acting as the trustee of a regulated debtor’s estate (within the meaning of Schedule 2 to the Bankruptcy Act 1966)
a circumstance specified in the AML/CTF Rules
Barristers, and privilege
Two provisions matter to the legal profession specifically. Section 6(6B) takes barristers out where they are briefed by a solicitor: a service is not a designated service “if the service is provided by a person in the course of legal practice as a barrister on the instructions of a solicitor, if the instructions are given in connection with the provision of a designated service”. The obligation stays with the instructing firm.
And section 242 is one sentence long: “This Act does not affect the law relating to legal professional privilege.” The machinery around claiming it — including the Minister’s power to make guidelines under section 242A — came in with Schedule 4 of the Amendment Act. Privilege survives the regime; it is not a reason to stay outside it.
What we checked ourselves
The Rules barely mention Table 6 at all
The AML/CTF Rules 2025 are where the operational detail lives. It is reasonable to expect a sector as new as this one to have a chapter of its own. It does not. Search the current compilation of the Rules for “table 6” and there are three occurrences, all of them item 1 — real estate. Items 2 to 9 have no provisions of their own anywhere in the instrument.
s 5‑20
Policies relating to customer due diligence for real estate transactions
Applies to a reporting entity providing a service covered by item 1 of table 5 or item 1 of table 6 that participates in a reliance arrangement.
s 6‑32
Delayed initial customer due diligence — real estate transactions
Permits a service to commence before initial CDD finishes; subsection (3) is the limb that covers item 1 of table 6, where the customer is the buyer or transferee.
s 6‑33
Initial customer due diligence — real estate transactions
The reliance arrangement for collecting and verifying KYC information, available where the only service proposed is item 1 of table 5 or item 1 of table 6.
s 9‑4A
Matters to be taken into account — real estate brokering
Makes a customer’s failure to cooperate a matter to be taken into account in forming a suspicion, in the circumstances described in s 6‑33.
So for items 2 to 9, the general provisions are the whole of it: enrolment, the AML/CTF policies, customer due diligence, reporting, record keeping. The exclusion hooks the Act leaves open for the Rules — paragraphs 6(5C)(f), 6(5D)(b) and 6(5E)(c) — have nothing hanging on them yet. That is worth knowing before you go looking for a rule that would resolve a hard question about your own practice. There isn’t one.
A qualifier we could not find in the law
Where does item 2’s “controlling interest” come from?
AUSTRAC GUIDANCE AND STARTER KITS
“This only applies where the sale, purchase or transfer relates to a controlling interest in the body corporate or legal arrangement.”
AUSTRAC, Professional services (reform); and Accountants — Risk assessment, January 2026
THE ACT — s 6(5B) TABLE 6, ITEM 2
“…to sell, buy or otherwise transfer a body corporate or legal arrangement, where: (a) the service is provided in the course of carrying on a business; and (b) the sale, purchase or other transfer is not pursuant to, or resulting from, an order of a court or tribunal”
No controlling-interest qualifier appears in the item
The qualifier narrows item 2 considerably — on AUSTRAC’s reading, selling a minority parcel of shares would sit outside the item, and on the Act’s words it would not obviously be outside anything. We could not locate the qualifier in section 6 of the Act or anywhere in the Rules, so in July 2026 we asked AUSTRAC directly where it comes from, along with three related questions about items 2 to 9.
We asked AUSTRAC · July 2026
In July 2026 we wrote to AUSTRAC asking four questions: whether ss 5‑20, 6‑32, 6‑33 and 9‑4A are the only provisions of the Rules that apply specifically to Table 6; whether rules are intended under the exclusion hooks; whether sector-specific rules or class exemptions for items 2–9 are planned; and what the legislative or interpretive source of the controlling-interest qualifier is.
AUSTRAC’s contact centre replied that the Rules provide the detail for the broader obligations set out in the Act, and that where the Rules are silent the Act has already set out the requirement; that the starter kits are approved by AUSTRAC and derived from the legislation; and that any further amendments to the Rules will be communicated to industry. We were pointed to the published professional-services guidance. No provision was identified as the source of the qualifier. AUSTRAC notes that its correspondence is general information and not legal advice.
That is a fair description of how the regime is built — the Act carries the obligation and the guidance explains it. It also leaves the qualifier where we found it: in guidance rather than in the instrument. So if your matter is a non-controlling transfer of an interest in a company or a trust, the practical course is to note that AUSTRAC’s published position puts it outside item 2, record that you have relied on that position, and take your own advice — rather than assume the narrowing is in the law itself.
The neighbouring table
Real estate agents are in Table 5, not Table 6
Subsection 6(5A) has two items, and they cover the agent and the developer rather than the professional advising on the deal. Between Table 5 and items 1 and 3 of Table 6, a single property transaction can involve three or four reporting entities at once.
THE ACT — s 6(5A) TABLE 5, ITEM 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”
Customer of the designated service: “both: (a) the seller or transferor; and (b) the buyer or transferee”
THE ACT — s 6(5A) TABLE 5, ITEM 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”
Customer of the designated service: “the buyer or transferee”
The other neighbouring table
Bullion and precious metals are Table 2, and it works differently
Dealers arrive at Table 6 often, because “dealers in precious metals and stones” are named as one of the newly regulated sectors. But the professions that advise on a deal are in Table 6, while the businesses that buy and sell the goods sit in Table 2, in subsection 6(3). Table 2 turns on value thresholds and payment method rather than on assisting — nothing in it uses the language you have just read.
THE ACT — s 6(3) TABLE 2, ITEM 1
“buying or selling bullion, where the buying or selling is in the course of carrying on a bullion‑dealing business”
Customer of the designated service: “the buyer or the seller (as the case may be)”
The Act defines bullion as gold, silver, platinum or palladium in the relevant forms. Section 39E exempts item 1 where the retail value of the bullion is less than $5,000.
THE ACT — s 6(3) TABLE 2, ITEM 2
“buying or selling one or more of the following items in the course of carrying on a business, where the purchase involves the transfer of physical currency or virtual assets (or a combination of physical currency and virtual assets) with a total value of not less than $10,000, whether the purchase is made in a single transaction or in several transactions that are linked or appear to be linked: (a) precious metal; (b) precious stones; (c) precious products; (d) any combination of any 2 or more of the items referred to in paragraphs (a) to (c)”
Customer of the designated service: “the buyer or the seller (as the case may be)”
The $10,000 threshold bites on physical currency or virtual assets, not on the sale price — a $60,000 ring paid for by card is not item 2; the same ring paid for with $10,000 cash and the rest by card is. “Precious product” is defined widely in s 5A and reaches jewellery, watches and objects of personal adornment.
A dealer can be in both tables at once. Selling the stock is Table 2; if the same business also creates entities for clients, holds their money in a transaction, or provides a registered office, those are Table 6 services with their own obligations.
Table 2 asks what was sold and how it was paid for — not who assisted whom
In the order you should trust them. The instruments bind; the guidance explains and does not. Where the two differ, the instruments control — and a deliberate departure from guidance is something to record with reasons.
Every quoted provision was compared word for word against the compiled Act and Rules rather than retyped from guidance. Items 1, 3 and 6 of Table 6 were checked against Compilation No. 62 of the Act (C2026C00274); the complete table, together with subsections 6(5C), 6(5D), 6(5E), 6(6B) and section 242, was checked against Compilation No. 61 (C2026C00220), and the wording is identical wherever the two overlap. The Rules search was run over Compilation No. 1 (F2026C00274). Everything attributed to AUSTRAC is guidance and is labelled as such.
Compilations change. Before you rely on any of this, open the current compilation on the Federal Register of Legislation and read section 6 for yourself — the point of quoting it here is that you can.
Published 16 February 2026 · last checked against the Register 13 August 2026
Whether your business is a reporting entity depends on the designated services you provide — not on having an ABN or being based in Australia. Check AUSTRAC’s sector guidance, and seek professional advice for your situation.
Knowing you are caught is the easy part
Lex-AML is being built for the work that starts once you know: the program, the customer due diligence, the evidence and the audit trail your obligations leave behind.
Educational purposes only. This content is general information only. It is not legal, financial or compliance advice. Organisations should check AUSTRAC guidance, legislation, their own AML/CTF Program and professional advice where needed.
Published by GetPost Labs Pty Ltd, a technology company building compliance software. Nothing here is legal, financial or compliance advice, and it does not determine whether your business is a reporting entity — that depends on the designated services you actually provide. Every provision is quoted so you can check it yourself against the Federal Register of Legislation, and you should. If you spot an error, tell us at sumit@getpostlabs.io and we will fix it.
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