AML for bookkeepers: tax work versus a designated service
AML for bookkeepers is a designated-service question. A BAS on its own is not the reason to sell a check.
Quick answer
AML for bookkeepers follows the engagement, not the job title. A BAS, a tax return, and ordinary bookkeeping on fixed instructions are often outside a designated service. Only offer a check where the service is designated. When a check is required, it is client-pays. The firm suite is A$0.
A search for “aml for bookkeepers” usually comes from a practice that lodges activity statements and keeps the books, and wants to know whether that work just became an AML product. It did not, by itself. Tax work and a designated service are different questions. The sector pillar is AML for accountants: designated services. This page is the bookkeeping cut. 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. The wider map is /tranche-2.
Tax work versus a designated service
The letterhead does not enrol the practice. The engagement on this file does. AUSTRAC’s examples are the source. The rows below are a sorting aid for a bookkeeping book. Confirm the file on their page before you treat it as in or out.
A sorting aid for bookkeeping and tax work. AUSTRAC’s examples stay on their professional services page. This table does not reproduce them.
| Work on the file | Usual reading | Reopen the question if |
|---|---|---|
| A BAS, a tax return, or financial statements, and nothing else | Often outside a designated service | The job grows into forming the company, selling it, or holding money for a deal |
| Payroll, suppliers, rent, utilities, loan repayments, and GST, paid from the client’s account on fixed instructions | AUSTRAC’s bookkeeping example is less likely to be managing client money, where you cannot redirect the funds | You can redirect the money, or you also provide another designated service |
| Tax advice on the implications of selling a company, with no transaction yet | Often not yet the sale service. Advice can influence the client without advancing a sale | You are instructed to act on a sale, or negotiations with a buyer have started |
| The firm’s address used as a company’s registered office, while the company operates somewhere else | Often a designated service to that company | You are only the landlord of the premises where the company actually sits |
- Ordinary bookkeeping is not a funnel. Processing the client’s bills on fixed instructions is the example AUSTRAC uses for work that is less likely to be in. Do not verify the whole book “just in case”.
- The comfort is narrow. It weakens if the practice can redirect the funds, or if the same client also receives another designated service, such as a registered office or a nominee arrangement.
- Tax advice is not the sale. Advice on the tax effect of a sale can sit outside until the firm is instructed to move the transaction. The order of questions is the designated services decision tree.
Only where the engagement is designated
Sell FreeAML on the file that is in scope. Do not sell a check on a BAS that is outside. Once the service is designated, the day-to-day check is AML checks for accountants. The software shape, if you are comparing monthly seats, is AML software for accountants. A longer practice checklist remains Tranche 2 for accountants.
A bookkeeper who is not the reporting entity does not acquire the firm’s duties by preparing the books. If the accounting practice provides the designated service, that practice enrols, names the officer, and runs customer due diligence under its program. The bookkeeper follows that program. This page does not appoint anyone.
Client-pays when a check is actually needed
A monthly AML seat on a book of tax clients is a cost attached to work that is often outside the regime. The FreeAML firm suite is A$0. There is no seat to carry through a quarter of BAS lodgements. When a file is designated and the program requires a verification, the firm sends the request by email and the check 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. How the client is asked to pay, without describing it as a government charge, is client-pays KYC.
FreeAML does not decide that a bookkeeping engagement is a designated service, does not enrol the practice, and does not replace austrac.gov.au. The firm suite holds the customer file for the matters that are in. The matters that are out do not need a check to justify the software.
📚 Related Resources
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Frequently Asked Questions
A check only where the service is designated.
The firm suite is A$0. When a file is in scope, the client completes the verification by email.
View pricingQuestions: team@freeaml.com.au