AML/CTF Compliance Software
Built for Accountants
Australian accountants and tax agents face new anti-money laundering obligations under AUSTRAC Tranche 2. ComplyAU assists you in building, maintaining, and evidencing your AML/CTF program before the July 1, 2026 deadline.
What Tranche 2 Means for Accountants
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 extends Australia's AML/CTF regime to professional service providers including accountants, tax agents, and BAS agents. This is commonly known as “Tranche 2” and represents the most significant expansion of Australia's anti-money laundering framework since the original Act commenced in 2006.
For the first time, accountants providing certain services will be classified as “reporting entities” under the AML/CTF Act 2006. This means you will need to enrol with AUSTRAC, implement a formal AML/CTF program, conduct customer due diligence on your clients, report suspicious matters, and maintain records for a minimum of 7 years.
AUSTRAC estimates that approximately 100,000 businesses across Australia will be brought into the regime under Tranche 2. For accounting practices, the compliance burden is real: you will need documented policies, trained staff, risk assessments, and systems to manage ongoing obligations. The penalty regime is severe, with civil penalties reaching millions of dollars and criminal penalties including imprisonment for serious failures.
The commencement date is 1 July 2026. AUSTRAC enrolment opens 31 March 2026. The time to prepare is now.
Your Obligations Under the AML/CTF Act
The following obligations apply to accountants and tax agents providing designated services under s6AA of the AML/CTF Act 2006.
Enrol with AUSTRAC (s75C)
All reporting entities providing designated services must enrol with AUSTRAC before commencing those services. For Tranche 2 entities, enrolment opens March 31, 2026.
Establish an AML/CTF Program (Part 7A)
You must develop, implement, and maintain a written AML/CTF program with two parts: Part A covers your risk-based procedures for customer identification, ongoing due diligence, and transaction monitoring. Part B covers your employee due diligence program.
Customer Identification (CDD) (s28–35)
Before providing a designated service, you must verify your client’s identity using reliable and independent documentation or electronic verification. Enhanced CDD applies to high-risk clients including politically exposed persons (PEPs) and clients from high-risk jurisdictions.
Ongoing Customer Due Diligence (s36)
CDD is not a one-off exercise. You must conduct ongoing monitoring of your business relationships, including updating client information and scrutinising transactions that are inconsistent with your knowledge of the client.
Suspicious Matter Reporting (SMR) (s41–49)
If you form a suspicion on reasonable grounds that a transaction or matter may relate to money laundering, terrorism financing, or another serious offence, you must lodge a suspicious matter report with AUSTRAC within the prescribed timeframe. Failure to report carries serious criminal penalties.
Record Keeping (Part 10)
You must retain all CDD records, transaction records, and AML/CTF program records for a minimum of 7 years. Records must be stored securely and be accessible to AUSTRAC upon request.
Tipping-Off Prohibition (s123)
It is a criminal offence to disclose (‘tip off’) a client or third party that an SMR has been, is being, or will be made. Penalties include imprisonment.
How ComplyAU Assists Accountants
ComplyAU provides the tools and workflows to help you meet your AML/CTF obligations. Every feature is designed for the specific needs of accounting and tax advisory practices.
AML Program Generator
AI builds your complete Part A and Part B AML/CTF program tailored to accounting and tax advisory services. Aligned with AUSTRAC guidance for professional service providers.
Client Identification Workflows
Guided CDD and ECDD workflows with document verification checklists, PEP screening, sanctions checks, and beneficial ownership identification for trusts and companies.
Suspicious Matter Reporting
Structured SMR forms with AUSTRAC-aligned fields, real-time validation, and a complete audit trail. Never miss a reporting deadline.
7-Year Record Retention
Automatic document retention with encrypted storage. Every CDD check, every transaction record, every decision documented and retrievable for AUSTRAC examinations.
Risk Assessment Engine
Client and transaction risk scoring aligned with AUSTRAC’s risk-based approach. Automatically flags high-risk indicators including PEPs, sanctioned jurisdictions, and unusual transaction patterns.
Staff Training Portal
AML/CTF training modules tailored for accounting staff. Track completions, issue certificates, and satisfy your Part B employee awareness obligations.
TPB Registration and AML/CTF Compliance
The Tax Practitioners Board has signalled that AML/CTF compliance will be a relevant factor in assessing fitness and propriety under the Tax Agent Services Act 2009 (TASA). A failure to comply with your AUSTRAC obligations could constitute a breach of the Code of Professional Conduct, potentially putting your TPB registration at risk.
This creates a dual compliance imperative: you need to satisfy both AUSTRAC and the TPB. ComplyAU helps you maintain audit-ready evidence that supports both regulatory relationships, with exportable compliance reports and training records that demonstrate your ongoing commitment to your obligations.
Frequently Asked Questions
When do accountants need to comply with AML/CTF obligations?
The AML/CTF Amendment Act 2024 (Tranche 2) commences on 1 July 2026. AUSTRAC enrolment opens on 31 March 2026. Accountants and tax agents providing designated services under s6AA of the AML/CTF Act 2006 must be enrolled and have their AML/CTF program in place by the commencement date.
Which accounting services are designated services under Tranche 2?
Under s6AA of the AML/CTF Act 2006 (as amended), designated services for accountants include: providing financial advisory services, tax advisory services, preparing for or carrying out transactions involving the creation, operation, or management of trusts, companies, or other legal entities, and managing client money or assets. Not all accounting services are captured — standard bookkeeping and tax return preparation may be excluded depending on the specific service provided.
Do I need to report my existing clients or only new ones?
Your AML/CTF program must cover both new and existing client relationships. For new clients, you must complete CDD before providing a designated service (s28–35). For existing clients (your ‘back-book’), you must conduct CDD at the next appropriate opportunity or when you identify a higher risk. AUSTRAC expects a risk-based approach to back-book remediation.
What are the penalties for non-compliance?
Penalties under the AML/CTF Act are significant. Failure to enrol carries civil penalties up to 100,000 penalty units ($31.3 million for a body corporate). Failure to have an AML/CTF program, failure to report suspicious matters, and tipping-off offences carry both civil and criminal penalties, including imprisonment for individuals. AUSTRAC also has infringement notice and enforceable undertaking powers.
How does the TPB interact with AML/CTF obligations?
The Tax Practitioners Board (TPB) has indicated that compliance with AML/CTF obligations will be relevant to maintaining your registration as a tax agent or BAS agent. Non-compliance with AUSTRAC requirements could constitute a breach of the Code of Professional Conduct under the Tax Agent Services Act 2009 (TASA). This means AML/CTF failures could affect both your AUSTRAC standing and your TPB registration.
Does ComplyAU replace the need for legal advice?
No. ComplyAU is a compliance management tool that assists you in meeting your AML/CTF obligations. It does not provide legal advice. For specific questions about how the legislation applies to your practice, you should consult a qualified legal professional. ComplyAU helps you build, maintain, and evidence your compliance program — but the legal responsibility remains with you as the reporting entity.
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Sources
All information on this page is based on the following primary sources. This page does not constitute legal advice.
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Federal Register of Legislation)
- AML/CTF Rules 2024 (Federal Register of Legislation)
- AUSTRAC \u2014 Tranche 2 Information (austrac.gov.au)
- AUSTRAC \u2014 Enrolment Guidance (austrac.gov.au)
- FATF Recommendations (Financial Action Task Force)
- Tax Practitioners Board (tpb.gov.au)
Start Preparing for Tranche 2 Today
Join the waitlist for early access to ComplyAU. Start your 14-day free trial and build your AML/CTF program before the deadline.
Join the WaitlistAUSTRAC enrolment opens 31 March 2026. Tranche 2 commences 1 July 2026.