Back to Blog
Compliance
October 4, 20269 min read

AML for insolvency practitioners

An insolvency appointment is made under other law. That appointment is not, by itself, the designated service of forming a company or setting up a trust; the same practice can still provide a designated service on different work.

Quick answer

Separate the appointment from the rest of the practice. A liquidator, voluntary administrator, or bankruptcy trustee is already regulated. That regulation is not the AML/CTF program. Pre-appointment work that establishes an entity can be in scope while the appointment is not; shareholder checks on a members’ voluntary liquidation are a different page; do not paste a trading-company pack onto every creditor; the client pays a check only where the program requires one.

People search “AML for insolvency practitioners” when an accounting practice takes liquidation appointments and also forms companies, and the staff are using one customer pack for both. 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. Shareholder checks on a members’ voluntary liquidation are MVL shareholder KYC. Which accounting services are designated is designated services for accountants. The sector map is /tranche-2.

The appointment is not the whole practice

A registered liquidator or a bankruptcy trustee answers to a statute that is not the AML/CTF Act. Staff hear insolvency and reach for a customer pack anyway. The right cut is the service.

Taking an appointment over a company is not the act of forming that company for a client. Work done before the appointment, if it sets up a new entity, can be a designated service the accounting page already discusses. Creditors in a liquidation are not a queue of KYB checks merely because they are owed money.

  • Appointment. Record it as the other statute’s job unless the program has named it as a designated service, which this page does not do for you.
  • Entity setup. Pre-appointment company or trust work is assessed on the accountants’ designated-services page.
  • Members’ voluntary liquidation. Shareholder identification on that path has its own page. Do not merge it into every creditors’ meeting.
  • Creditors. A proof of debt is not a customer of a designated service by default.

One practice, different files

Sorting an insolvency practice’s files. This table does not reproduce AUSTRAC’s professional-services guidance.

FileFirst questionWhat to resist
Liquidation or administration appointmentIs this the other statute’s appointment, or a designated service the program named?A full KYB pack on every creditor
Bankruptcy trustee appointmentSame cut, different statuteTreating the petition as an AML program
Pre-appointment company formationIs that work a designated service?Hiding it inside the later appointment
Members’ voluntary liquidationUse the shareholder pageIgnoring members because a liquidator was appointed

Where the insolvency page stops

This page separates an insolvency appointment from entity work. It is not the members’ voluntary liquidation note, and it is not the full list of accounting designated services. Those are MVL shareholder KYC and designated services for accountants.

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. An insolvency appointment is not a KYB check, and the firm suite does not include one for every creditor. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that an insolvency appointment is a designated service.

Frequently Asked Questions

Check the service, not the letterhead.

The firm suite is A$0. The client pays a check only where your program requires it. The firm emails the link.

Open the Tranche 2 guide

Questions: team@freeaml.com.au