Accounting firms are not brought into scope simply because they are accountants. The trigger is providing a Table 6 designated service. This guide shows which common accounting work is caught and which is not.
Quick answer
Tax work is not the trigger. Transactions and structures are.
Tax returns, BAS and bookkeeping are not in Table 6. Common Table 6 examples include company and trust formation, client money, business transactions and certain office or company roles. Use the table below to check the work, not the profession label.
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.
The “Where” column shows whether each row is a designated service, an exclusion in the Act or an example from AUSTRAC’s guidance. Caught rows link to the article that covers them in full.
| Area | The work | Caught? | Where |
|---|---|---|---|
| Tax and compliance | Preparing tax returns, lodging BAS and bookkeeping, with no authority over client money | Not caught | Not a Table 6 service |
| Client money | Holding authority to make payments from a client’s bank or securities account, including under a power of attorney | Caught | Item 3 |
| Client money | Receiving your own fees | Not caught | s 6(5C)(a) |
| Business sales | Due diligence, or valuing assets and liabilities, in anticipation of the sale of a company | Caught | Item 2 |
| Business sales | Tax advice on selling a company, before there is a transaction or an identified buyer | Not caught | AUSTRAC guidance, item 2 |
| Finance | Preparing loan or subscription documents for a company raising debt or equity | Caught | Item 4 |
| Finance | General advice on financing options where nothing is being organised, planned or executed | Not caught | AUSTRAC guidance, item 4 |
| Structuring | Registering a company with ASIC, or drafting a trust deed and facilitating its execution, on instructions | Caught | Item 6 |
| Structuring | Merging or splitting companies, or converting a company limited by guarantee to one limited by shares | Caught | Item 6 |
| Structuring | General advice on the benefits of a structure, and a referral to someone who will create it | Not caught | AUSTRAC guidance, item 6 |
| Corporate services | Selling a shelf company to a client | Caught | Item 5 |
| Corporate services | Arranging for a staff member to act as secretary or director of a client’s company | Caught | Item 7 |
| Corporate services | Providing your office as a client company’s registered office — even free of charge | Caught | Item 9 |
| Corporate services | Providing a mailing address or PO box only | Not caught | AUSTRAC guidance, item 9 |
| Insolvency | Acting as trustee of a regulated debtor’s estate under Schedule 2 to the Bankruptcy Act 1966 | Not caught | s 6(5E) |
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: the person. Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), s 6(5B) — table 6.
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: 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. Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), s 6(5B) — table 6.
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: the person to whom the service is provided. Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), s 6(5B) — table 6.
Lex-Brisbane Accounting, a fictional Brisbane firm, helps its client James Brown, a builder and sole trader, create a company. Gregory Bentham, the firm’s AML/CTF compliance officer, runs the matter in the Lex-AML Organisation Workspace; James only uses the Customer Portal.
One example of how a matter in an accounting firm can run in Lex-AML, which is configured around each organisation’s own AML/CTF program. The business and its customers are fictional, the identity and screening checks use demo providers, and no real customer information is shown. The organisation makes every customer due diligence decision. Not legal advice.
In the order the Act sets them, once the business provides a designated service.
If this is work you do
Lex-AML starts by recording the designated services your firm actually provides, then helps you organise your AML/CTF program, customer due diligence and audit trail around them.
Which company, trust, transaction and client-money services can bring accounting work into scope.
Sources
Data as at 13 October 2026.
Lex-AML supports compliance workflows and record keeping. It does not provide legal advice, does not guarantee compliance, and does not replace professional judgement or advice from a qualified AML/CTF adviser or legal professional.