AML compliance for Australian professional services firms — the complete 2026 guide

Why AML compliance now applies to professional services firms

Australia's financial intelligence agency AUSTRAC has identified accounting professionals as key 'gatekeepers' to the financial system. Accountants who help clients set up companies, manage trusts, and handle transactions can — sometimes unknowingly — be used to launder the proceeds of crime or finance terrorism.

The AML/CTF Act was amended in 2024 to extend obligations that banks have operated under since 2006 to accountants, lawyers, real estate agents, and conveyancers. These are known as Tranche 2 reforms.

Which accounting services are in scope?

Not all accounting services trigger AML obligations. Your firm is in scope if you provide any of these designated services:

• Forming or managing companies, trusts, partnerships, or other legal arrangements
• Acting as or arranging nominee directors, trustees, or shareholders
• Managing client funds or bank accounts
• Buying or selling businesses or business assets on behalf of clients
• Acting on property transactions on behalf of clients

Services like tax returns, BAS preparation, and general bookkeeping are generally not in scope — but most professional services firms that offer structuring, wealth management, or business advisory services will be captured.

What compliance actually looks like in practice

For a typical accounting firm with 40 clients receiving designated services, AML compliance involves:

• Verifying the identity of each client and their beneficial owners
• Documenting the risk each client poses
• Writing (and annually reviewing) an AML/CTF program for the firm
• Monitoring clients for suspicious activity on an ongoing basis
• Keeping records of everything for 7 years
• Reporting suspicious matters to AUSTRAC when required

Managing AML compliance for your clients — the bigger opportunity

Many small businesses that need to comply with Tranche 2 themselves will look to their accountant for help. This creates a genuine commercial opportunity: offering AML compliance as a managed service, at 00–300 per client per month, is a significant new revenue stream.

The challenge is doing it efficiently. Managing compliance for 30 clients using spreadsheets and manual processes is impractical. Purpose-built software with a multi-client dashboard — like CompliDesk — makes it manageable.

Penalties for non-compliance

AUSTRAC has made enforcement clear from the outset. Civil penalties for breaching the AML/CTF Act can reach 2 million for serious breaches. Criminal penalties including imprisonment apply for deliberate non-compliance. AUSTRAC publishes enforcement actions — reputational damage is as significant as financial penalties for professional firms.