Managing client money: the trigger many accountants miss

People search “managing client money AML accountant” when a suburban practice lets settlement funds sit in the trust account for a week and still describes itself as a tax firm only. 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. The wider list of services is Table 6 designated services. Which accounting services are in scope is AML for accountants: designated services. The sector map is /tranche-2.

The tax return is not the test

A lot of accounting firms will never hold a dollar of client money, and their designated-service question is about other work, such as forming companies. The firms that get this wrong are the ones that 'just help' with a settlement, a business sale, or a short transfer between the client and a supplier. The favour is the service. The engagement letter's first line does not cancel it.

You are looking at whether you receive, hold, or control the funds, even for days. A trust account that exists only for those weeks is still a trust account. Cash paid across the front desk is a different report, covered on the threshold page, and it is not a reason to ignore the managing-money question.

• Name the flow. Who sends the money, whose account it sits in, and who you pay. If the answer runs through the firm, write it down.
• Short stays still count. A week in the trust account is not 'too brief' to think about. Duration is not a comfort.
• The label is irrelevant. 'Bookkeeping client' and 'tax client' are not exemptions. The service is.
• Separate the other triggers. Forming a company, or acting as trustee, is a different designated-service question. Do not use this page to answer it.

Four accounting desks, one question

Where the client-money page stops

This page is the client-money trigger accountants skip. It is not the full designated-service list and it is not every accounting service. Continue on Table 6 designated services and AML for accountants: designated services.

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. Noticing that you handle client money is not the customer check, and each verification the program then requires is client-pays. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that managing client money is a designated service on your file.

Frequently Asked Questions