Accountant as nominee director
An accountant who agrees to be a nominee director is taking an appointment, not just preparing accounts. If that appointment is a designated service, customer due diligence comes before you accept it.
Quick answer
Accountant nominee director AML work sits in the program only if you actually take the role. Preparing a tax return is a different sentence from sitting as director for someone else. A nominee arrangement is sensitive because another person is meant to be the real controller. Do not accept the office until the program's due diligence is done, and the client pays any check.
People search “accountant nominee director AML” when a suburban accounting practice is offered a nominee director appointment and wonders if the tax-agent file already covers it. Checked against AUSTRAC's professional designated services page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. How table 6 items are sorted is table 6 designated services. Which accounting services are in scope is designated services for accountants. The sector map is /tranche-2.
The appointment is its own sentence
Accountant nominee director AML questions start with a plain sentence: will this firm hold the office of director for a client. If the answer is yes, you are not in the same job as lodging the return. Table 6 is where the firm looks for the item that covers acting as a director for someone else. This page does not quote that item and does not decide it for you.
The risk is structural. A nominee is there so someone else can stay off the public office. That is a reason to know who owns and controls before you accept, not a reason to skip the question because the client is old.
- Split the services. Tax agent work, company accounts, and a directorship are three descriptions. Only the ones you provide belong in the program.
- Do the due diligence before the consent. Accepting first and checking later reverses the order.
- Ask who the real controller is. If the client cannot say, you are not ready to be the name on the record.
- Write the refusal rule. The program should say the firm does not take the office while due diligence is open.
Nominee, or something quieter
Practices slide into the role. They sign a consent because the shelf company needs a second director this afternoon. Sort the signature before it happens. A one-off consent is still an appointment.
What the accountant is actually being asked to do. This table does not reproduce table 6 or AUSTRAC's professional services page.
| Ask | If yes | Do not confuse it with |
|---|---|---|
| Will we be named as director? | Treat it as a possible designated service until the program classifies it | Reviewing the financial statements |
| Is the client the real controller? | Due diligence has to reach that person | The person who sent the consent form |
| Is this only for a week? | A short appointment is still an appointment | A favour that the program can ignore |
| Do we already prepare the tax? | That file does not accept the office for you | A reason to skip a fresh check |
Where the nominee page stops
This page is the nominee-director question for an accounting firm. It is not the whole of table 6. The sorting page is table 6 designated services.
A registered office with no directorship is a different service. Do not treat this page as the answer to that one.
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 nominee appointment is not prepaid inside the firm suite, and the individuals the program names are still separate checks. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a nominee appointment is a designated service or accept the office for you.
📚 Related Resources
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Frequently Asked Questions
Name the appointment in the program before you accept it.
The firm suite is A$0. The client pays the checks the program requires before you take the role.
Open the Tranche 2 guideQuestions: team@freeaml.com.au