The challenge
AUSTRAC tranche 2 AML/CTF compliance
Accounting firms that provide designated services are expected to become reporting entities under AUSTRAC's AML/CTF regime from 1 July 2026 (subject to passage of legislation). This represents a signific compliance change for the accounting profession in Australia.
AUSTRAC tranche 2 AML/CTF compliance
Accounting firms that provide designated services are expected to become reporting entities under AUSTRAC's AML/CTF regime from 1 July 2026 (subject to passage of legislation). This represents a signific compliance change for the accounting profession in Australia.
What triggers AML/CTF obligations?
Firms providing ANY of these designated services will be reporting entities and must comply:
1. Company formation and administration
2. Trust establishment and trustee services
3. SMSF setup and administration
4. Partnership formation
5. Business acquisitions and sales
6. Director/nominee services
7. Registered office services
8. Property transactions
9. Tax planning involving structures
Firms providing ANY of these designated services will be reporting entities and must comply:
1. Company formation and administration
2. Trust establishment and trustee services
3. SMSF setup and administration
4. Partnership formation
5. Business acquisitions and sales
6. Director/nominee services
7. Registered office services
8. Property transactions
9. Tax planning involving structures
Core obligations for reporting entities
Customer Due Diligence (CDD)
Verify identity of clients receiving designated services before provision of those services.
Personnel Due Diligence (PDD)
Screen employees performing AML/CTF functions for skills, integrity, and expertise.
Suspicious Matter Reporting (SMR)
Report suspicious transactions to AUSTRAC. Cannot tip off clients.
AML/CTF Programme
Written, Board-approved programme addressing ML/TF risks.
Record-Keeping
Maintain transaction and CDD records for 7 years AUSTRAC Enrolment Each legal entity must enrol by 29 July 2026.
Customer Due Diligence (CDD)
Verify identity of clients receiving designated services before provision of those services.
Personnel Due Diligence (PDD)
Screen employees performing AML/CTF functions for skills, integrity, and expertise.
Suspicious Matter Reporting (SMR)
Report suspicious transactions to AUSTRAC. Cannot tip off clients.
AML/CTF Programme
Written, Board-approved programme addressing ML/TF risks.
Record-Keeping
Maintain transaction and CDD records for 7 years AUSTRAC Enrolment Each legal entity must enrol by 29 July 2026.
The stakes: Penalties for Non-compliance
Civil penalties up to $31.1 million per entity (for corporations) for serious breaches. Criminal penalties including imprisonment for serious contraventions. Reputational damage and regulatory scrutiny.
Pathway 1: Build your own capability
How it works
We train your Compliance OƯicer to become the
internal AML expert. Your staff learn procedures
and own the processes. 12-month support, then
you operate independently.
What you get
• Programme design (Part A)
• CDD/PDD/SMR procedures
• Technology platform guidance
• Staff training (all levels)
• 12-month ongoing support
• AUSTRAC enrolment support
• Knowledge transfer: YOU become expert
Best for
Best for: Mid-sized firms (4+ partners) wanting
long-term cost savings and internal control
Long-term: Independent operation after Year 1 (optional ongoing support available)
Pathway 2: Outsourced AML Compliance Officer
How it works
We act as your external AML Compliance Officer under annual service contract. We handle compliance functions for you. You focus on clients - we handle AML/CTF.
What you get
• CDD processing oversight
• SMR identification and lodgement (where formally appointed as compliance officer)
• Transaction monitoring
• Compliance testing and reporting
• AUSTRAC liaison
• Procedure updates
• Training refreshers
Best for
Best for: Smaller firms (1-3 partners) or firms preferring
expert oversight without internal resourcing
Long-term: Ongoing annual contract (renewable). We
remain your compliance officer.View our complete Avenue AML offering
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Capital Markets Advisors