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October 4, 20269 min read

Client money for a property deposit held by the accountant

Holding a property deposit can be a designated service for an accountant, separate from preparing the tax return. The program has to test the holding, not assume only conveyancers touch deposits.

Quick answer

Write down whose money it is, which transaction it belongs to, and whether your program treats receiving or holding it as a designated service. The item list is the test. A long tax relationship does not answer it. Cash at the threshold is a different report; the firm emails a link if CDD applies; the client pays.

People search “accountant holds deposit AML” when a suburban accountant has been asked to hold a buyer’s property deposit in the firm account. Checked against AUSTRAC’s professional designated services on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The item list is discussed on Table 6 designated services. Which accounting services are in scope more broadly is on AML for accountants’ designated services. The sector map is /tranche-2.

The deposit is a different instruction

A client asks the accountant to “just hold the deposit until the contract goes unconditional.” The tax file is familiar. The money is new. Professional designated services include client-money items. If receiving or holding that deposit is one of them for your practice, you are not doing a favour beside the tax return.

You are providing a designated service, and customer due diligence follows. Do not assume the conveyancer’s trust account is the only place a deposit can trigger the item. The question is what your firm is doing with the money. If you refuse to hold it, say so, and do not half-hold it in a clearing account while you decide; this page does not number the item; the table of services is a different page; this page also does not say every client account balance is in scope.

  • Name the money. Whose funds, for which property, and how long you will hold them.
  • Test the item. Read the client-money designated service against that description. Do not test it against your job title.
  • Then do CDD on that customer. The person you do tax for may not be the customer of the holding.
  • Keep the cash report separate. Physical currency at the threshold is not decided by this page.

Sort the request the day it arrives

The partner who takes the call can sort it before the money moves. Once the funds are in the account, the fact pattern is already the holding.

Sorting a deposit request at a tax practice. This table does not reproduce AUSTRAC’s professional designated services.

FactQuestion for the programDifferent page
Asked to hold a property depositIs this the client-money itemThe conveyancer’s trust account
Preparing the tax returnUsually not this itemDo not let the return answer the deposit
Cash notes at the thresholdA report question if physical currency was received in scopeThe threshold-report guide
Company or trust as the clientWho the customer isKYB, not only the individual who rang

Where the deposit page stops

This page is the accountant asked to hold a property deposit. It is not the full item table and it is not every accounting designated service. Those are Table 6 designated services and AML for accountants’ designated services. FreeAML does not hold the money and does not classify the item.

The firm suite is A$0. If the program requires a check, the client pays it.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. The firm suite does not include holding the deposit or deciding that the holding is a designated service. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that holding a deposit is a designated service or hold the money.

Frequently Asked Questions

If the holding is in scope, verify the customer.

The firm suite is A$0. The client pays. KYC for a person. KYB if the customer is a company or a trust.

Start an AML check

Questions: team@freeaml.com.au