Author: FeeSynergy
Regulatory Background
Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act (introduced in 2006) is expanding under Tranche 2 Reforms, which passed on 29th November 2024. These amendments extend compliance obligations to professional service providers such as accountants, lawyers, real estate agents, and trust service providers.
- Firms must enrol with AUSTRAC from 31st March 2026
- Compliance is mandatory from 1st July 2026
Who Needs to Comply?
Accounting practices must comply if they provide designated services, including but not limited to:
- Managing client funds (e.g. trust accounts, investments).
- Trust and company formation services (e.g., setting up legal structures, concealing ownership).
- Nominee services (acting as or arranging nominee directors, shareholders, or trustees).
- Providing a registered office or correspondence address.
- Engaging in financial transactions on behalf of clients (e.g., property purchases, business sales)
AML/CTF vs. TPB Proof of Identity (POI)
AML/CTF compliance goes beyond the Tax Practitioner Board’s (TPB) POI checks. It requires:
- A comprehensive compliance program
- Appointment of an AML/CTF Compliance Officer
- Regular staff training & independent reviews
- Annual compliance declarations to AUSTRAC
Building an AML/CTF Program
An AML/CTF Program must identify and mitigate risks based on:
- Customer profiles
- Services offered
- Delivery methods
- Foreign jurisdictions involved
Part A: Risk Assessment
This forms the foundation of your AML/CTF Program. It involves:
- Evaluating your firm’s exposure based on client types, services offered, delivery channels, and geographical risks
- Considering the nature and complexity of the business
- Identifying the likelihood and impact of potential money laundering or terrorism financing risks across different parts of your business
- Documenting how these risks are identified and managed
Part B: AML/CTF Policy
This outlines the procedures and controls your firm will implement to comply with AML/CTF obligations and mitigate the risks identified. It should include:
- Governance and oversight arrangements, including a designated AML/CTF Compliance Officer
- Staff training on AML/CTF risks, red flags, and internal procedures
- Customer identification and verification procedures, including how you verify clients and beneficial owners
- Ongoing customer due diligence and enhanced due diligence for higher-risk clients
- Transaction monitoring and suspicious matter reporting processes
- Screening processes for politically exposed persons (PEPs)
- Employee due diligence measures to ensure staff involved in AML/CTF processes are trustworthy and appropriately vetted
Getting Started
Accounting firms should begin planning now. FeeSynergy, in partnership with One AML, offers:
- RegTech solutions for identity verification (biometrics, document verification, AML checks)
- Consulting services for AML/CTF Program development
- Group-wide compliance frameworks for national accounting firms
Next Steps:
Firms should assess their obligations and take action before the 2026 deadlines to avoid penalties. For a more in-depth explanation read our three part series beginning with Tranche 2 Reforms – What Accounting Firms Need to Know Now or contact FeeSynergy.
Tranche 2 Reforms – What Accounting Firms Need to Know Now
The Clock is Ticking on AML/CTF Compliance
If you run an accounting practice in Australia, major regulatory changes are on the horizon. The Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act Tranche 2 Reforms have officially passed, and accounting firms will now be required to comply with stricter anti-money laundering laws.
Key Deadlines:
- Enrol with AUSTRAC from 31st March 2026
- Full compliance required from 1st July 2026
But what does this mean for your accounting practice? Let’s break it down.
Understanding AML/CTF Compliance for Accountants
The AML/CTF Act, originally introduced in 2006, regulates businesses at risk of being exploited for money laundering or terrorism financing. Until now, professional service providers—such as accountants, lawyers, and real estate agents—have largely been exempt.
The Tranche 2 Reforms change that. If your practice provides designated services, you will have compliance obligations.
Does Your Accounting Firm Need to Comply?
If you offer any of the following services (or other designated services not listed), your practice will be subject to AML/CTF regulations:
- Managing client funds (e.g., trust accounts, investments, payments on behalf of clients)
- Company formation services (e.g., setting up legal structures, registering companies)
- Nominee services (e.g., acting as a director, trustee, or shareholder)
- Providing a registered business address for clients
- Financial transactions for clients (e.g., handling property purchases, business sales)
If your practice engages in any of these activities you should act now to prepare for compliance before the 2026 deadlines.
In Part 2, we’ll explore what an AML/CTF Program looks like and what you need to do to ensure your firm is ready. How to Build an AML/CTF Program for Your Firm.
How to Build an AML/CTF Program for Your Accounting Firm
AML/CTF Compliance: What Your Firm Needs to Do
As part of Australia’s Tranche 2 AML/CTF Reforms, accounting firms will need to establish a risk-based program. This is not just a tick-the-box exercise—it requires detailed policies, procedures, staff training, and ongoing reporting.
So, what exactly does an AML/CTF program involve?
The Two Key Parts of an AML/CTF Program
Under the reforms, firms must develop two key documents tailored to their specific risk profile and service offerings:
Risk Assessment
This forms the foundation of your AML/CTF Program. It involves:
- Evaluating your firm’s exposure based on client types, services offered, delivery channels, and geographical risks
- Considering the nature and complexity of the business
- Identifying the likelihood and impact of potential money laundering or terrorism financing risks across different parts of your business
- Documenting how these risks are identified and managed
AML/CTF Policy
This outlines the procedures and controls your firm will implement to comply with AML/CTF obligations and mitigate the risks identified. It should include:
- Governance and oversight arrangements, including a designated AML/CTF Compliance Officer
- Staff training on AML/CTF risks, red flags, and internal procedures
- Customer identification and verification procedures, including how you verify clients and beneficial owners
- Ongoing customer due diligence and enhanced due diligence for higher-risk clients
- Transaction monitoring and suspicious matter reporting processes
- Screening processes for politically exposed persons (PEPs)
- Employee due diligence measures to ensure staff involved in AML/CTF processes are trustworthy and appropriately vetted
Remember: Your AML/CTF Program must be reviewed regularly and independently evaluated every three years to ensure it is effective and compliant.
What’s Next?
Compliance is not just about paperwork—it also requires technology solutions to streamline identity verification, risk assessments, and reporting. In Part 3, we’ll discuss how your firm can leverage RegTech solutions and expert guidance to simplify AML/CTF compliance. Tech Solutions & Expert Support for AML/CTF Compliance.
AML/CTF Compliance Made Easy – Tech Solutions & Expert Support
The Challenge of AML/CTF Compliance
With Australia’s Tranche 2 AML/CTF Reforms coming into effect, many accounting firms are wondering: How do we ensure compliance without overloading our team with administrative work?
The good news? Technology and expert guidance can make compliance far more manageable.
RegTech: The Smart Approach to AML Compliance
Traditional AML compliance can be time-consuming, but RegTech (Regulatory Technology) solutions automate key processes, saving your firm time and reducing human error.
FeeSynergy’s AML Compliance Platform includes:
- Biometric verification – Facial recognition with liveness detection
- Optical character recognition (OCR) – Automated ID document scanning
- Real-time data verification – Checking IDs against government databases
- AML/CTF screening – Politically Exposed Persons (PEP) and sanctions checks
- Comprehensive reporting – Centralised dashboards for compliance tracking
Why Expert Guidance Matters
Implementing an AML/CTF Program isn’t just about technology—it requires expert-led program development, staff training, and ongoing support. That’s why FeeSynergy has partnered with One AML, a leading AML/CTF consultancy.
- Tailored AML/CTF Programs – Designed for your firm’s risk level and services
- National compliance frameworks – For multi-office accounting groups
- Ongoing training & support – Keeping your staff informed and compliant
Final Thoughts: Take Action Now
Compliance deadlines are approaching fast. If your accounting firm provides designated services, you must be ready by 1st July 2026.
Next Steps:
- Assess if your firm falls under AML/CTF obligations
- Start building your AML/CTF Program (risk assessment, policies, procedures and controls)
- Leverage RegTech solutions to streamline compliance
- Get expert support to ensure compliance before the deadline
By acting now, you can avoid penalties, protect your business, and ensure a seamless transition into AML/CTF compliance.
Need Help? Contact FeeSynergy to explore AML compliance solutions tailored for accounting firms.
For more information from AUSTRAC, please click here.