AML Tranche 2 for accountants: the compliance checklist
Accountants and tax advisers providing designated services are captured by AML/CTF Tranche 2 from 1 July 2026. This checklist covers capture, enrolment, your program, CDD and reporting.
Are accountants captured?
Accountants and tax advisers are included within the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime by Tranche 2, effective from 1 July 2026. This means certain activities undertaken by accounting professionals will be subject to new compliance obligations. To determine whether your firm falls within the scope of Tranche 2, use the AML Tranche 2 scope checker.
The key factor in determining whether an accountant is captured by Tranche 2 is whether they are providing a ‘designated service’. These services are specifically listed and include activities such as managing client money or assets, forming companies or trusts, buying or selling business entities, or acting as a registered office or nominee.
Routine tax-return preparation, in isolation, is generally considered lower-risk and is unlikely to trigger AML/CTF obligations. However, if your practice provides any of the designated services, you will be subject to the requirements of the regime.
Key dates
AUSTRAC enrolment for accountants under Tranche 2 opens on 31 March 2026. Accountants must use this opportunity to register with AUSTRAC. Further information on the enrolment process can be found in the AUSTRAC enrolment guide.
The commencement date for AML/CTF obligations for Tranche 2 accountants is 1 July 2026. This marks the point at which these obligations become legally binding.
Enrolment for the first wave of Tranche 2 accountants closes on 29 July 2026. Failure to enrol by this date may result in civil penalties of up to $19,800 per day.
Your AML/CTF program
Your AML/CTF program must include both a Part A and a Part B program. Part A covers areas such as risk assessment, governance, employee training, and ongoing monitoring. Part B details the customer due diligence procedures your firm will implement.
A key requirement is the appointment of an AML/CTF Compliance Officer. This individual must be given sufficient authority to fulfil their responsibilities within the program.
AUSTRAC provides a sector starter template to assist in developing your program. Firms should tailor this template to accurately reflect their own specific risks.
CDD, monitoring and reporting
Accountants must undertake customer due diligence (CDD) before providing a designated service. This includes verifying the customer’s identity and identifying beneficial owners beneficial owner identifier (any individual owning or controlling at least 25%) and politically exposed persons.
Ongoing monitoring is also required. Accountants must file Suspicious Matter Reports within 24 hours of forming a suspicion, and Threshold Transaction Reports for cash transactions of $10,000 or more within 10 business days.
Records relating to CDD and transactions must be retained for a period of 7 years.
- Suspicious Matter Reports: within 24 hours
- Threshold Transaction Reports: within 10 business days
Frequently asked
Does preparing tax returns trigger AML Tranche 2?
Routine tax-return preparation alone is generally lower-risk. The trigger is providing a listed designated service such as managing client money, forming companies or trusts, or acting as a nominee. Use the scope checker to confirm.
When must accountants enrol with AUSTRAC?
Enrolment opens 31 March 2026 and closes 29 July 2026 for the first wave. Obligations commence 1 July 2026.
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