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October 4, 20269 min read

Red flags for accountants, translated from AUSTRAC indicators

Suspicious activity indicators for accountants are prompts the program uses. They are not a copied AUSTRAC list and they are not an automatic report.

Quick answer

Translate an indicator into a question on this file: what is unusual here, and do we have a suspicion. A regional tax practice writes that question in its own words. Forming a suspicion is a separate step from noticing a prompt. This page does not reproduce AUSTRAC’s indicators and it does not say how to file.

People search “suspicious activity indicators accountants” when a tax practice wants a local list of accountant warning signs and is about to paste a regulator page into the program. Checked against AUSTRAC’s risks and indicators page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. How a report is made, once you have a suspicion, is the suspicious matter report for Tranche 2. Which accounting work is in scope is designated services for accountants. The sector map is /tranche-2.

Prompts for a tax practice, not a pasted list

Accountants see patterns banks also see, but the file is a tax practice: a request to move value with no business behind it, a structure that appears the week a deal settles, a client who will not explain a payment the firm is asked to touch. AUSTRAC publishes indicators. This page does not copy them. Your program should name the prompts that match the designated services you provide, in words your staff can use.

An indicator is a reason to look. It is not, by itself, a decision that you suspect money laundering or terrorism financing. Write what you saw, what you asked, and whether a suspicion was formed. The report, if you form one, is a different page.

  • Start from services you provide. A prompt about holding client money matters only if you hold client money. Do not import an indicator for a service you do not offer.
  • Use practice language. “Client will not say where the settlement money came from” is usable. A pasted paragraph from a regulator PDF is not training.
  • Separate look from suspicion. The prompt puts the file on the review pile. The suspicion decision is a later line, made by the person the program names.
  • Do not brief the client on the prompt. Telling a client which fact worried you can become a tipping-off problem. Say what the engagement needs. Do not describe a possible report.

Four accountant scenes

These are scenes a tax practice can recognise. They are not AUSTRAC’s list and they are not a scoring model. Each one ends with the same question: do we have a suspicion on this file.

Scenes for an accounting practice. This table does not reproduce AUSTRAC’s indicators.

What the practice seesThe prompt in plain wordsWhat it is not
A new company with no apparent business, days before a large paymentWhy does this entity exist nowAn automatic report
A client asks the firm to pass on funds the firm does not usually holdAre we being asked to move valueA reason to invent a new service
Records for a deal do not match the story in the emailWhich story is the fileA completed review, if you only noticed
Urgency, and a refusal to name the people behind a trustWho is missing, and why the rushA full suspicion, until someone decides

Where the accountant indicators stop

This page is the prompt for an accounting practice. It is not the report and it is not the designated-service test. Those are the suspicious matter report for Tranche 2 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. Reading an indicator is not a customer check, and the firm suite does not include a suspicion decision. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that you have a suspicion or file a report for the practice.

Frequently Asked Questions

A prompt is not a report. A check is still client-pays.

The firm suite is A$0. The client pays when the program requires verification. FreeAML does not decide a suspicion.

Start an AML check

Questions: team@freeaml.com.au