Accountants
AML/CTF obligations for accountants: what's in scope and how to check clients
Being an accountant does not by itself make your practice a reporting entity. The services you provide decide it.
AUSTRAC's guidance on professional designated services is profession neutral. The same rules apply whether the work is done by an accountant, a lawyer or another adviser. What matters is whether you take active steps that directly advance a specified transaction, or the creation or restructure of an entity, and whether the service has a geographical link to Australia.
For many practices that means most of the work you do each week, such as tax returns, BAS and bookkeeping, is not automatically captured. The services that are more likely to be captured are the ones where you help set up, restructure, fund or transfer an entity, or where you act in a role for a client's entity. Giving general advice, or providing an ancillary service that merely influences a transaction, is not enough on its own, according to AUSTRAC.
If some of your services are designated services, your obligations already apply. Newly regulated businesses providing designated services have been regulated since 1 July 2026. Your practice needs to be enrolled with AUSTRAC, and you need a risk assessment, AML/CTF policies and customer due diligence for the relevant clients.
A sensible starting point is to list every service line, mark which ones may match AUSTRAC's descriptions, and confirm the borderline ones against the guidance. Keep the list with your scope assessment and update it when you add or change services.
Scope
What is and isn't usually in scope.
Services that can be designated services
- Creating or restructuring a company, trust or other legal arrangement for a client
- Selling a shelf company
- Assisting with the sale or transfer of control of a body corporate or legal arrangement
- Arranging equity or debt finance for a client's entity
- Acting as, or arranging for someone to act as, a director, secretary, trustee or nominee in specified circumstances
- Providing a registered office or principal place of business address in place of the client's operational address (even if you do this for free)
- Receiving, holding, controlling or managing a client's money or property to advance a specified transaction, subject to exceptions
Not automatically captured
- Routine tax return preparation and lodgement, which is not automatically captured
- Bookkeeping and BAS work, which is not automatically captured
- General advice that does not take active steps to advance a specified transaction
These are summaries. Apply the exact criteria in AUSTRAC's guidance to each service before deciding. An SMSF client is not automatically in scope; the service you provide to it is what counts. Not sure? Try the readiness checker.
Example workflow
A practical onboarding sequence.
- 1
Classify the engagement
Before you start, decide whether the engagement includes a designated service. Record why.
- 2
Send an InvestPass link
For an individual, send an individual check. For a company or trust, start an entity check and add each beneficial owner.
- 3
Confirm owners and controllers
Record anyone who ultimately owns 25% or more, and anyone who otherwise controls the entity, such as an appointor of a trust.
- 4
Handle PEP and sanctions results
Escalate any potential sanctions match to your compliance officer before doing any work. Apply enhanced due diligence where required.
- 5
Rate the client and record it
Rate the client under your documented policies and professional judgement, and keep the result on the client file. Our free client risk rating tool can support that assessment but cannot replace it.
- 6
Keep records
CDD records are generally kept for 7 years after the business relationship ends or after the last occasional transaction.
This is an example only. Adapt it to your own AML/CTF policies.
Identity check vs program
A check is one step, not the whole job.
An InvestPass check helps with one part of customer due diligence: verifying identity and gathering ownership details. It does not by itself make you compliant. You still need your ML/TF risk assessment, AML/CTF policies, a compliance officer, PEP and sanctions handling, ongoing due diligence, reporting and record keeping. AUSTRAC states that a digital identity check alone is not full AML/CTF compliance.
When to check
Moments that usually need a check.
- Onboarding a new client
- Registering a company or trust for a client
- Creating or restructuring a trust or company for an SMSF, where that is a designated service
- Acting as a director, secretary or trustee for a client
Individual check
ID, face match and AML screening on the client's phone.
Company check
Directors, shareholders and owners for company clients.
Trust and SMSF check
Trustee, deed and members or beneficiaries.
Good to know
Tips for your team.
- Check existing clients over time, starting with those you set up entities for.
- Add a service charge to pass the cost on, once client payments are available.
General information only, not legal advice. Check your own obligations with AUSTRAC guidance or a qualified adviser.
Pricing
Pay per check. No monthly fee.
Individual Verification
FeaturedIndicative, to be confirmed
$20per person · GST included
Identity and AML screening for one person.
- Identity verification
- ID document and liveness
- PEP, sanctions and watchlists
- Risk assessment
Entity Verification
Indicative, to be confirmed
$40per entity · GST included
Company, trust or SMSF verification.
- ABN / ACN and business details
- Directors, trustees and shareholders
- Trust deed collection
- Entity screening
Beneficial Owner Verification
Indicative, to be confirmed
$20per owner · GST included
Each beneficial owner of an entity: owns 25% or more, or otherwise controls it.
- Identity verification
- PEP and sanctions screening
- Linked to the entity report
Indicative, to be confirmed. Prices in AUD, GST included.
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