AML/CTF requirements for Australian accountants

Am I in scope?

You may be in scope where you provide designated professional services — for example managing client money, assets or accounts, or assisting with the creation or restructuring of companies or trusts.

For authoritative sector guidance, see AUSTRAC’s accountants guidance.

Accountants — what the law actually asks

Which accounting services put a practice in scope — company and trust formation, managing client money, acting on transactions — read from s 6, table 6 rather than from the profession’s name.

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If you provide a designated service

The next step is not a generic checklist. The reporting entity needs an AML/CTF program appropriate to its business and risks, and must apply the customer due diligence, training, reporting, review and record-keeping obligations relevant to the services it provides.

What this can look like inside an accounting practice

The AML/CTF trigger is the designated service, not the profession label. For example, where a practice is assisting with a company or trust structure, or handling another service covered by Table 6, the practice first identifies the relevant designated service and then operates its own AML/CTF program for that work.

1. 01Check the serviceConfirm which designated service applies to the engagement rather than assuming every accounting service is covered.
2. 02Open the engagementRecord the customer, engagement and relevant designated service so the AML/CTF work has clear context.
3. 03Complete the required customer due diligenceCollect and review the information and evidence required by the practice’s AML/CTF program.
4. 04Review risk and make the decisionThe practice reviews the customer and engagement information and makes the relevant compliance decisions. Lex-AML supports the workflow; it does not make the decision for the practice.
5. 05Keep the evidence connectedRetain the relevant CDD information, supporting evidence, reviews, decisions and audit history with the engagement.

Illustrative only. This is a worked example of how the workflow can run — not legal advice, not a statement that every accountant or every accounting service is covered, and not a substitute for checking the service against the Act and AUSTRAC’s guidance.

AML/CTF training built for accountants

People performing functions relevant to your AML/CTF obligations need training appropriate to their role, risks and responsibilities. Lex-AML Academy teaches the core regime and includes sector-specific lessons built around the AUSTRAC material used by your profession.

Common questions