What Australian Accountants Need to Know About the New AML/CTF Laws
From 1 July 2026, accountants who provide certain services will be subject to Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime. If your firm is involved in setting up companies or trusts, managing client funds, providing registered office services (providing an address for a registered office or principal place of business is sufficient), or assisting with financial transactions, these changes will almost certainly affect you.
This article outlines the key changes, what they mean for accountants, and how to prepare.
Why the Change?
The AML/CTF regime is being extended to bring accountants, lawyers and other professional advisers into the regulatory net. This is in response to international standards from the Financial Action Task Force (FATF), which require countries to regulate “designated non-financial businesses and professions”.
Accountants often assist in high-risk areas—such as business structuring, trust establishment, asset transfers, or acting as nominee directors. These activities can be exploited to disguise or move illicit funds. The reforms aim to close that gap.
What’s the Legislative Status?
Known as “Tranche 2”, the new legislation has already passed Parliament. It comes into effect for most professional firms on 1 July 2026, with a few services commencing earlier.
Much of the detail—such as key definitions, exemptions, and thresholds—will appear in subsidiary rules that are still being finalised. These are expected by the end of 2025.
What Services Are Covered?
The new regime applies to so-called “designated services”. For accountants, these may include:
Acting for or assisting clients to buy or sell real estate
Creating or restructuring companies, trusts, or other legal entities
Providing a registered office or business address for a client
Managing client money, property, or digital assets
Assisting with capital raising or lending arrangements
Acting as or arranging nominee directors, trustees or shareholders to act for another person
A service is only “designated” if it is provided in the course of business and not under a court or tribunal order (with some exceptions).
In practical terms, if your firm offers any of these services from 1 July 2026, you will be a reporting entity and subject to AML/CTF obligations.
More detail is available in Table 6 of Section 6 of the new Act, which we’ve made available on our website. Some terms—like “assisting” or “acting for”—are still being clarified, and AUSTRAC is expected to release guidance by the end of 2025.
What Will Accountants Need to Do?
By 1 July 2026, affected firms must:
Enrol with AUSTRAC – Australia’s financial intelligence agency
Appoint a Compliance Officer – typically a partner or senior staff member
Create an AML/CTF Program – documenting how your firm will manage risk
Perform Client Due Diligence (CDD) – including identity verification and risk assessment
Report suspicious matters to AUSTRAC
Maintain records – including checks, assessments, and internal reports
These are not one-off tasks. Your AML program must be kept up-to-date, and your systems reviewed regularly to reflect changes in your services and the broader risk environment. Regular compliance reporting and reviews will also be required.
What Are the Penalties?
Breaching AML/CTF obligations can lead to significant financial and reputational damage. Some high-profile cases include:
Westpac – $1.3 billion
Crown (Melbourne & Perth) – $450 million
TAB – $45 million
While those are large institutions, AUSTRAC has also imposed penalties on small firms—often between $3,000 and $20,000. For many accountants, the more serious consequence could be the professional impact of non-compliance, including disciplinary action or reputational harm.
What Should You Do Now?
It’s too early to build out your full compliance framework—the rules are still being finalised—but we recommend taking the following steps now:
Understand how accounting services can be misused for money laundering
Identify which of your services may be captured
Allocate responsibility internally, including identifying a likely compliance officer
Start thinking about how AML/CTF processes might integrate with your existing workflows
We suggest firms begin practical planning by September 2025.
What Are AUSTRAC’s Expectations?
On 3 July 2025, AUSTRAC released a statement outlining its expectations for new reporting entities. By 1 July 2026, AUSTRAC expects you to:
Be enrolled as a reporting entity (enrolment opens 31 March 2026)
Have an AML/CTF Program in place (a starter program will be available from December 2025)
Have a Compliance Officer appointed
Have trained your staff on your AML/CTF obligations
Be ready to ask clients questions and report suspicious activity
You can read AUSTRAC’s expectations here: AUSTRAC’s statement – 3 July 2025
We’re Here to Help
At Halseys, we’ve been working in the AML/CTF space since 2010. We’re a boutique firm and understand the pressures on small and medium-sized practices. We’ll continue to publish practical updates for accountants as the reforms unfold.
If you'd like to join our AML/CTF mailing list, just get in touch at amlctf@halseys.com.au. We're here to help you prepare sensibly, without unnecessary cost or disruption.
We’re Here to Help
We’re a law firm with deep experience in financial services and AML/CTF regulation—we’ve been working in this space since 2010. We’ll continue to provide updates as more information becomes available. We’re a small firm, and we understand the realities of small to medium firm practice. Our principal was a director and in-house counsel at EY, giving us insight into accounting firms.
If you'd like to receive our AML/CTF updates, please email us at amlctf@halseys.com.au and we’ll add you to our mailing list.
Other Resources
You can connect with Fiona Halsey on LinkedIn, or join the LinkedIn AMLCTF Group for Australian Accountants. You might enjoy watching some of our short videos, which are the Essentials for Accountants series (you can access these through LinkedIn from Fiona Halsey’s profile).
Summary Only
This article is a summary only and you should not make decisions on the basis of this article – you should obtain legal advice.