Designated services — Table 1 of section 6 AML/CTF Act

Why the list matters

The list of designated services, as detailed in section 6 of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), is significant because it determines which entities are subject to stringent AML/CTF obligations. A person providing a designated service to a customer is classified as a ‘reporting entity’ under section 5 of the Act. AML Tranche 2 complete guide

Being a reporting entity triggers a range of requirements. These include enrolment with AUSTRAC, the development and maintenance of an Anti-Money Laundering and Counter-Terrorism Financing program, conducting customer identification procedures, lodging suspicious transaction reports, and maintaining appropriate records.

Table 1 outlines designated financial services, while Table 2 and Table 3 cover bullion and gambling services respectively. The upcoming Tranche 2 reforms will expand this list to include designated services provided by lawyers, accountants, real estate professionals and trust and company service providers, commencing 1 July 2026.

Table 1 — categories

Table 1 outlines categories of designated services under the *Anti-Money Laundering and Counter-Terrorism Financing Act*. These categories cover core financial services, including account-based services, lending, foreign exchange, remittance, currency exchange, debit/credit cards and stored-value cards.

The designated services within these categories are specific actions, such as opening, maintaining or making available an account, and lending under various structures. Other designated services include issuing or selling securities or derivatives, and acting as a trustee or making a person a beneficiary of a trust where prescribed.

Each category in Table 1 is accompanied by conditions. These conditions determine whether a particular service falls within the scope of the designated services.

Table 2 and Table 3

Table 2 of section 6 of the AML/CTF Act designates bullion dealing as a designated service. This includes activities such as buying, selling, exchanging and trading bullion.

Table 3 designates gambling services as a designated service. This encompasses operating gambling venues, providing online wagering, conducting lotteries and accepting bets.

Casinos are subject to a separate AML/CTF Rules regime, reflecting the higher money laundering and terrorism financing risk identified by the FATF. Online wagering operators are reporting entities for activities including accepting bets, paying winnings and operating customer accounts.

How to assess scope

Reporting entities determine their scope of obligations by carefully examining each customer interaction and comparing it against the rows listed in Table 1, Table 2, and Table 3. If any designated service, as defined in Table 1, is provided to any customer, the reporting entity must complete an AUSTRAC enrolment 31 March 2026 walkthrough and enrol with AUSTRAC within 28 days of commencing the service.

An entity may provide multiple designated services. In such cases, the entity’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) program must adequately address and cover all designated services being provided.

Captured entities remain subject to their obligations until they cease providing all designated services and complete the de-enrolment process. Failure to enrol after providing a designated service constitutes an offence under section 51E and carries substantial penalties.