AML for accountants: which services are designated after 1 July 2026

This is the sector pillar for designated services in an accounting practice. It is general information, not legal advice, and it is not a copy of the Act. The source is AUSTRAC’s professional designated services guidance. The wider map is /tranche-2. A members’ voluntary liquidation is a different article. The day-to-day check, once a service is in, is a different article again.

Routine tax is not the trigger

AUSTRAC’s own example is an accounting firm giving tax advice on the implications of selling a company. That advice can influence the client. It does not, by itself, directly advance a sale, and there is no transaction yet. The designated service begins when the firm is instructed to act on a sale: one buyer is clear, or negotiations have started with a potential buyer. From there, negotiating, drafting or reviewing the contract, valuing the assets for the sale, preparing settlement, and preparing the ASIC transfer are the steps that advance the outcome.

The same idea covers a tax return or a BAS lodged on its own. The letterhead does not enrol the practice. The engagement on this file does. If the tax job grows into forming the company or selling it, reopen the question. Do not verify every historical tax client “just in case”.

Sort the engagement

Three rows firms misread

• Bookkeeping. AUSTRAC’s example is a practice that processes payroll, suppliers, rent, utilities, loan repayments, and GST from the client’s business account, on fixed instructions, with no discretion to redirect. That is less likely to be managing the money. The comfort disappears if the practice also provides another designated service, such as a registered-office address or arranging a nominee. Read the example before you rely on it.
• The address. An accounting firm that lets a company use the firm’s address as its registered office, while the company operates somewhere else, is providing a designated service to that company. The landlord of the real premises is not, merely because the company sits there. A post office box is not the address this item is about.
• Creating the company. Registering the company, drafting the constitution, or preparing the trust deed is not “just ASIC forms”. For a new company, proposed beneficial owners and directors sit on the customer list with the person who instructed you. Identifying only the partner who sent the email is the gap.

What this page is not

It is not the workflow for running the check. Once the service is in, use AML checks for accountants. It is not the members’ voluntary liquidation question. A solvent wind-up is not, by itself, a file on every shareholder. That test is MVL shareholder KYC. It is not the all-sector tree. The order of questions for any Tranche 2 file is designated services decision tree. A longer practice checklist remains Tranche 2 for accountants.

If the row says in

A “yes” means you are likely a reporting entity for that service. Enrolment, the written program, and customer due diligence are the next jobs. They are not this table. If the row says out, write one sentence a colleague can audit: which question failed, and what would reopen the file. “We only do tax” is not a reason if this engagement is a company formation.

Where FreeAML fits

FreeAML does not tell you that a service is designated. Your program does, with advice where two readings fit. When a check is required, the firm suite is A$0 and verification is client-pays by email. Amounts are on FreeAML pricing.

Frequently Asked Questions