AML for tax agents: TPB proof of identity is not AUSTRAC CDD
AML for tax agents starts with a split. The Tax Practitioners Board proof of identity is not AUSTRAC customer due diligence, and a tax return is not automatically a designated service.
Quick answer
Keep two files in your head. The TPB expects a tax agent to know the client. AUSTRAC customer due diligence applies when you provide a designated service, such as forming a company or taking a nominee role, if your program classifies that work as in scope. Passing the TPB step does not tick the AUSTRAC step, and when a check is required, the client pays it.
People search “AML for tax agents” when a tax agent has already done a TPB proof of identity and believes the AML check is therefore finished. 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. Accounting firms more broadly are AML for accountants. The checks themselves are AML checks for accountants. The sector map is /tranche-2.
Two regimes, one client
AML for tax agents is confusing because the same person walks in for a return and, sometimes, for a company or a trust. The Tax Practitioners Board proof of identity belongs to the tax-agent relationship. AUSTRAC customer due diligence belongs to a designated service under the AML/CTF program. Doing the first does not complete the second.
Many engagements never leave the return. This page does not say every tax agent is a reporting entity for every client. It says you must not use the TPB file note as a substitute on the day the work becomes a designated service.
- Name the engagement. A return, a formation, a trust deed, a directorship, and a registered office are different sentences.
- Keep the TPB note in its lane. It shows you knew the tax client. It is not the AML program's record.
- Do not import a document list. This page does not say what the TPB accepts, and it does not say what your AML program accepts.
- Start due diligence when the service changes. The old identity note does not roll forward.
Return versus designated service
A suburban tax practice can sort the week by the verb on the engagement. The verb decides which regime you are in. If you are unsure the verb is a designated service, use the accountants' designated-services page rather than stretching this one.
Tax-agent work beside AML work. This table does not reproduce TPB rules or AUSTRAC's professional services page.
| Engagement | The identity job | A false comfort |
|---|---|---|
| Prepare a return | The TPB expectation for a tax client | Calling that return a designated service without classifying it |
| Form a company | AUSTRAC customer due diligence if the program says it is in scope | The TPB check from last year's return |
| Act as nominee director | Due diligence before you accept, if it is in scope | A letter of engagement from the tax file |
| Hold a registered office | Its own classification | Assuming address-only is always outside |
Where the tax-agent page stops
This page is the split between TPB proof of identity and AUSTRAC customer due diligence. It is not the list of accounting designated services. That list is designated services for accountants.
It does not restate Tax Practitioners Board evidence rules. Do not treat any sentence here as a TPB checklist.
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. A TPB identity step is not a FreeAML check, and it does not use up the KYC or KYB fee. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a tax-agent engagement is a designated service or treat TPB proof of identity as customer due diligence.
📚 Related Resources
Accountant AML Toolkit →
Complete compliance toolkit for accounting firms.
AML Software for Accountants →
Best practices and tools for accounting compliance.
Free KYC Check →
Verify customer identity in 60 seconds. Government ID + AML screening.
Free AML Program →
Board-ready AML/CTF Program template. All 10 AUSTRAC sections included.
Risk Assessment Generator →
AI-powered ML/TF risk assessment. 20-page compliant report in 5 minutes.
Free AML Training →
Online courses for staff. CPD-certified certificates included.
Frequently Asked Questions
When the work is a designated service, email a fresh link.
The firm suite is A$0. The client pays. The TPB step is not this check. KYC is A$20. KYB is A$40.
Start an AML checkQuestions: team@freeaml.com.au