AML accounting: routine tax versus designated accounting services
AML accounting is a service test. Routine tax is often outside. A designated accounting service is the file that needs the check.
Quick answer
AML accounting follows the service, not the tax return. Routine tax and ordinary bookkeeping are often outside. A designated accounting service, such as forming a company or selling the entity, often is not. If the file is in, customer due diligence sits on that matter. On FreeAML the firm suite is A$0 and verification is client-pays.
A search for “aml accounting” is usually a principal asking whether the tax practice just became an AML product. It did not, by itself. Checked against AUSTRAC’s professional designated services on 2 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. It is a short cut, not the sector pillar. The full sorting aid is AML for accountants: designated services. The map of who is in the regime is /tranche-2.
Routine tax versus a designated service
A first sort only. The awkward file belongs on the designated-services page, then on AUSTRAC’s page. This table does not decide the engagement.
| Work on the desk | Usually | What to do next |
|---|---|---|
| A tax return, a BAS, or ordinary bookkeeping with no discretion to redirect funds | Often outside | Do not send a check to look thorough |
| Tax advice that only influences how a client might sell, with no instruction to act on a sale | Often outside, on AUSTRAC’s example | Reopen the question if you are then instructed to advance the sale |
| Forming or restructuring a company, selling or transferring the entity, or selling a shelf company | Often a designated service | Customer due diligence on that matter |
| Holding client money in a deal, a nominee role, or lending the firm’s address as a registered office | Often a designated service | Same. The quiet tax files stay quiet |
Bookkeeping on fixed instructions is the neighbouring cut, not this page. That note is AML for bookkeepers. The professional items across lawyers, accountants, and conveyancers are Table 6 designated services. Status follows the service you do provide: what a reporting entity means.
If this engagement is in
A yes on one file does not pull the historical tax list into customer due diligence. It does mean the practice is a reporting entity for the designated service, with enrolment, a program, and a check on that matter. The day-to-day workflow, once the service is in, is AML checks for accountants.
On FreeAML the firm suite is A$0, including in a month of ordinary tax work. When a designated matter needs a check, the firm emails the client. 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. Confirm the live amounts on FreeAML pricing. A company customer is a KYB question, not a second personal file for every shareholder. FreeAML does not decide the service.
📚 Related Resources
Accountant AML Toolkit →
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Frequently Asked Questions
The engagement is designated. Send the check.
The firm suite is A$0. The client pays by email. Leave the routine tax files alone.
Start an AML checkQuestions: team@freeaml.com.au