ML/TF risk questions for a tax-and-business accountant

People search “accountant ML TF risk questions” when a shopfront tax practice copies a law firm's risk questions and never mentions the trust account or the shelf companies. Checked against AUSTRAC's accounting starter kit step on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Customer-level pictures of low, medium, and high are a different page from this firm-level list, and the written assessment is the ML/TF risk assessment for Tranche 2. Which services are in scope is AML for accountants: designated services. The sector map is /tranche-2.

A tax practice is not a small law firm

The useful questions follow the work. A tax-and-business shop forms companies, lodges returns, sometimes holds a surplus for a client, and sometimes agrees to be the public face of a shelf company. Those are different facts from a law firm's court diary. Copying another profession's list leaves the real use of the practice off the page.

Answer with numbers you already know. How many new entities last year, how often money touched the firm, whether anyone in the office is a director of a client's company. A self-managed super fund that also asks you to move cash is a different pattern from a fund that only wants the return prepared.

• Client money, yes or no. If the firm receives funds, the assessment says so. Do not bury it under 'business services'.
• Entities you create. Forming or running companies and trusts is its own question, separate from preparing their tax.
• Nominee and address roles. Sitting as director, trustee, or registered office is a service, not a stationery favour.
• New work and overseas parents. A book that is mostly ten-year locals is not the same book as a stream of new groups with a parent you have not seen.

Questions that belong on the accountant's page

Where the accountant's questions stop

This page is the practice-level question list. It is not a rating of one client, and it is not the designated-service decision tree. Go to the ML/TF risk assessment for Tranche 2 and AML for accountants: designated services.

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's answers are not a billed check, and a customer the program then sends to verification still pays that check. Confirm the live amounts on FreeAML pricing. FreeAML does not answer the practice's risk questions or approve the assessment.

Frequently Asked Questions