AML Tranche 2 for accountants: the compliance checklist

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 opened on 31 March 2026. Further information on the enrolment process can be found in the AUSTRAC enrolment guide.

AML/CTF obligations for Tranche 2 accountants commenced on 1 July 2026 and are in force now.

Enrolment is due 28 days after you first provide a designated service — 29 July 2026 for firms providing designated services from 1 July 2026. If you missed it, enrol now. Each day you provide a designated service while unenrolled can be a separate contravention. AUSTRAC can issue an infringement notice of $21,840 (company) or $4,368 (individual) per contravention, or seek a civil penalty of up to $36.4M for a body corporate (maximum per contravention). AUSTRAC began issuing information notices to apparently unenrolled accountants, lawyers, real estate agents and jewellers on 28 August 2026.

Your AML/CTF program

Under the reformed AML/CTF Act, your AML/CTF program is an ML/TF risk assessment plus AML/CTF policies (this replaced the former Part A / Part B structure). The policies cover customer due diligence, ongoing monitoring, reporting, record keeping, personnel due diligence, training and governance. The whole program must be independently evaluated at least once every 3 years; for newly regulated firms the first evaluation is due between 30 June 2029 and 31 December 2030, depending on your AUSTRAC account number.

A key requirement is the designation of an AML/CTF compliance officer at management level, notified to AUSTRAC. This individual must be given sufficient authority to fulfil their responsibilities within the program.

Tranche 2 small businesses are also covered by the Privacy Act for their AML/CTF activities: under s 6E(1A) of the Privacy Act 1988, a small business operator that is an AML/CTF reporting entity is treated as an organisation for those activities, so the Australian Privacy Principles apply to the customer identification material you collect, even if your turnover is under $3M (Privacy Act 1988).

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 3 business days of forming a suspicion (24 hours where it relates to terrorism financing), 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 3 business days (24 hours for terrorism financing)
• Threshold Transaction Reports: within 10 business days