Do accountants and bookkeepers need to maintain a written AML/CTF program?

Maintain a written AML/CTF program. Under the reformed AML/CTF Act (in force for existing reporting entities from 31 March 2026 and for Tranche 2 entities from 1 July 2026), a reporting entity's AML/CTF program is an ML/TF risk assessment plus AML/CTF policies that mitigate and manage those risks — this replaced the former Part A / Part B structure. The policies cover customer due diligence, ongoing CDD, transaction monitoring, reporting, record keeping, personnel due diligence and training, governance and senior manager approval, and the designation of an AML/CTF compliance officer.

Trigger: Becoming a reporting entity.

Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 27 of those industries the answer for "Maintain a written AML/CTF program" is no. Accountants & bookkeepers is one of the 8 where the answer is different: yes.

The deciding fact for accountants and bookkeepers: Tranche 2 industry (Accountants & bookkeepers) — AML/CTF reporting entity from 1 July 2026.

About the industry: Professional accounting and bookkeeping firms. Captured by Tranche 2 when providing designated services such as managing client money or company formation.

Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires an AML/CTF designated service).

Each cell is the engine's outcome for a business in accountants & bookkeepers with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.

• Payments for the bookkeeper's own fees are excluded from item 3 (s 6(5C)–(5D)).
• Incidental payments where the practice provides no other designated service, such as a bookkeeper's routine payments for a client, are excluded from item 3.
• Payments to or from government, courts or licensed insurers are excluded from item 3.

AUSTRAC's accountant starter kit is written for small accounting practices. Before relying on it, test the practice against the kit's "who the starter kit is for" criteria, including the 15-personnel limit.

When due

Before providing the first designated service. Maintained on an ongoing basis, with independent evaluation at least once every 3 years.

Evidence to keep

ML/TF risk assessment, AML/CTF policies, governing body / senior manager approval records, compliance officer designation and AUSTRAC notification, training records, independent evaluation report.

Maximum penalty

Civil penalty of up to $36.4M (body corporate) or $7.28M (individual), maximum per contravention. Separate criminal offences also apply.

Regulator

AUSTRAC

Jurisdiction

Commonwealth (national)

• Customer due diligence (KYC) on every customer: Yes
• Designate an AML/CTF Compliance Officer: Yes
• Detect + enhance due diligence on Domestic + Foreign PEPs: Yes
• Enrol with AUSTRAC as a reporting entity: Yes
• Suspicious matter, threshold, and IFTI reporting to AUSTRAC: Yes
• Independent review of AML/CTF program: Yes
• All 23 answers for accountants & bookkeepers

• Real estate agents: Yes
• Lawyers & solicitors: Yes
• Conveyancers: Yes
• Trust & company service providers: Yes
• Precious metals & stones dealers: Yes
• Banks & ADIs: Yes
• Gambling & wagering: Yes