Compliance for Accountants & bookkeepers
Professional accounting and bookkeeping firms. Captured by Tranche 2 when providing designated services such as managing client money or company formation.
Published obligations that apply to accountants & bookkeepers (6)
- criticalCWLTHEnrol with AUSTRAC as a reporting entity
Tranche 2 entities must enrol with AUSTRAC within 28 days of first providing a designated service (29 July 2026 for services from 1 July 2026).
- criticalCWLTHMaintain a written AML/CTF program
Every reporting entity needs a documented AML/CTF program — an ML/TF risk assessment plus AML/CTF policies.
- criticalCWLTHComply with the TASA Code of Professional Conduct
Tax practitioners must observe honesty, competence, confidentiality, PI insurance, and (from 2025) expanded breach reporting.
- highCWLTHAPES 110 Code of Ethics for accountants
APES 110 binds CA ANZ, CPA Australia and IPA members (and auditors) to five ethical principles via a threats-and-safeguards framework — who it covers and the penalties.
- highCWLTHComply with Australian Auditing Standards (ASA)
Auditors must conduct audits per ASA — Aus equivalent of ISA, with Aus additions.
- highCWLTHMaintain TPB registration (tax/BAS agents)
Tax agents and BAS agents must be registered with the TPB and comply with the Code of Professional Conduct.
Applicability answers for accountants & bookkeepers
- Do bookkeepers need to enrol with AUSTRAC?
- Do accountants need to enrol with AUSTRAC?
- Do accountants and bookkeepers need to enrol with AUSTRAC as a reporting entity?
- Do accountants and bookkeepers need to maintain a written AML/CTF program?
- Does Customer due diligence (KYC) on every customer apply to accountants and bookkeepers?
- Does Suspicious matter, threshold, and IFTI reporting to AUSTRAC apply to accountants and bookkeepers?
- Do accountants and bookkeepers need to designate an AML/CTF Compliance Officer?
- Do accountants and bookkeepers need to detect + enhance due diligence on Domestic + Foreign PEPs?