AML/CTF compliance for accountants.
Tax agents, BAS agents, auditors and accounting practices handling client funds, tax affairs and financial structures are now captured under AML/CTF Tranche 2. New obligations take effect 1 July 2026.
- Clients reluctant to provide identification or source-of-funds documentation
- Unusually complex corporate or trust structures with no clear commercial rationale
- Requests to move money through trust accounts without a genuine underlying transaction
- Discrepancies between a client's declared income and their asset portfolio
- Clients seeking to structure transactions to avoid reporting thresholds
- Requests to create or administer entities in high-risk jurisdictions
- Unusual cash payments for professional services
- Clients with links to sanctioned individuals, entities, or countries
Designated Services for Accountants
Your AML/CTF obligations are triggered when you provide any of these designated services. If your practice offers even one of these, you must comply.
Managing Client Money
Handling client funds held in trust accounts, including receiving, holding, or disbursing money on behalf of clients.
Tax & BAS Services
Preparing tax returns, BAS statements, and providing tax planning advice where designated service thresholds are met.
Financial Statements
Preparing financial statements and providing advice on financial affairs, business structures, and arrangements.
Buying & Selling Businesses
Advising on or facilitating the purchase, sale, or transfer of businesses and business assets.
Company & Trust Formation
Assisting with the formation, registration, or administration of companies, trusts, and other legal structures.
Investment Advice
Providing advice on investment strategies, superannuation structures, and wealth management arrangements.
Your Compliance Requirements
As a reporting entity under the AML/CTF Act, your practice must meet these four core obligations for every client engagement involving designated services.
Client Identification & Verification
- Verify client identity before providing any designated service
- Identify beneficial owners of corporate clients and trusts
- Apply enhanced due diligence for high-risk clients and politically exposed persons
- Collect government-issued ID and verify against reliable sources
- Screen all clients against DFAT sanctions lists and PEP databases
Transaction Monitoring
- Monitor for suspicious transactions related to tax evasion or fraud
- Watch for cash transactions of $10,000 or more (threshold transactions)
- Flag unusual patterns in trust account activity
- Identify clients attempting to structure transactions below reporting thresholds
- Monitor for discrepancies between declared income and asset profiles
Record Keeping
- Retain all CDD records for a minimum of 7 years
- Maintain audit-ready documentation for every client engagement
- Keep copies of all identification documents collected
- Document risk assessments and ongoing monitoring outcomes
- Store all screening results with timestamps and decision rationale
Suspicious Matter Reporting
- Submit SMRs to AUSTRAC within 24 hours for terrorism-related matters
- Submit SMRs within 3 business days for all other suspicious matters
- Report threshold transactions (cash of $10,000+) within 10 business days
- Never disclose to the client that a report has been or will be filed
- Maintain internal records of all reports submitted
Trust Account Requirements
Accounting practices that hold client funds in trust accounts face additional monitoring obligations. You must:
- Monitor all trust account transactions for suspicious activity
- Report any cash deposits of $10,000 or more as threshold transactions
- Identify and report structuring: where clients split transactions to avoid thresholds
- Maintain detailed records of the source and purpose of all trust account funds
- Ensure trust account processes are documented in your AML/CTF program
The Challenge for Accountants
Accountants are trusted gatekeepers of the financial system. They manage client funds, prepare financial statements, advise on tax structures, and facilitate business transactions. This privileged position also makes accounting services attractive to those seeking to launder money or evade financial scrutiny.
Under Tranche 2, accounting practices of all sizes will need to implement customer due diligence procedures, develop formal AML/CTF programs, and report suspicious matters to AUSTRAC. This applies whether you are a sole practitioner or a large firm.
The scope includes tax agents, BAS agents, auditors, and financial planners providing designated services. If your practice manages client money, prepares financial statements, or advises on business structures, you are almost certainly captured.
For most accounting firms, the biggest challenge is building compliance infrastructure from scratch — without the budgets or specialist staff that banks have. That's exactly the gap Clear Check fills.
How Clear Check Helps Accountants
Purpose-built for accounting practices. Every feature maps directly to your compliance obligations.
Sanctions & PEP Screening
Screen clients against DFAT sanctions, PEP databases, and global watchlists before you begin any engagement. Results in seconds with a compliance-ready audit trail.
Covers obligation
Client identification
Risk Assessment Builder
Generate a sector-specific risk assessment for your accounting practice. Covers client types, services offered, geographic risk factors, and transaction patterns common to accounting.
Covers obligation
AML/CTF program
AML/CTF Program Builder
Create a compliant AML/CTF program with Part A (risk-based systems and controls) and Part B (KYC procedures) specifically designed for accounting firms.
Covers obligation
Program development
Automatic Audit Trail
Every screening check generates a timestamped, tamper-evident record. Export PDF reports for AUSTRAC inspections. Full 7-year retention built in.
Covers obligation
Record keeping
Training Modules
Online AML/CTF training modules for accounting teams. Covers red flags in financial transactions, CDD procedures, and reporting obligations. Track completion and issue certificates.
Covers obligation
Staff compliance
Get compliant before July 2026
Full AML/CTF screening and compliance tools from $49/month
No per-check fees on subscription plans. Australian hosted. No lock-in contracts.