AML/CTF legislation lands: Early preparation is key

Neville Birthisel

This article was current at the time of publication.

The reform of the anti-money laundering/counter-terrorism financing (AMF/CTF) regime will directly affect accountants providing professional services and will take effect from 1 July 2026. This may seem a long way off, but early awareness and preparation is key.

What’s next for AML/CTF?

Significant parts of the AML/CTF reforms, including the rules and guidance, are still under development. Accountants should be wary of providers offering solutions that claim to support compliance with the new regime given how much of the new regime remains to be finalised.

CPA Australia, with other stakeholders, is closely engaging with the Australian Transaction Reports and Analysis Centre (AUSTRAC) in the development of rules and guidance to support those who will be brought into the AML/CTF regime.

AUSTRAC has a dedicated page providing resources to support this reform. It is developing AML/CTF Starter Program Kits to assist small businesses transition to the new requirements.

Which professions are affected?

The AML/CTF Regime does not regulate industries, but rather the services being provided. 

Designated services will be expanded to include professional services typically provided by accountants and lawyers. These are included in a new Table 6 introduced by the amendment Bill. Professional services include, but are not limited to:

• Providing your address as the registered office address of your corporate clients.
• Assisting a client in a transaction to sell, buy or otherwise transfer real estate.
• Assisting a client in a transaction to sell, buy or otherwise transfer a business.
• Holding or managing a client’s money or other assets.
• Selling or transferring a shelf company.
• Assisting a client with a restructure.
• Acting as a director or nominee shareholder on behalf of a client.

Compliance dates

Providers of these services, known as reporting entities, must enrol with AUSTRAC. The timeframe for enrolment is 31 March 2026 to 29 July 2026.

Reporting entities must have an AML/CTF Program in place before providing designated services. These entities must conduct initial customer due diligence before providing a designated service, and “ongoing customer due diligence” in relation to the provision by the reporting entity of designated services.

AUSTRAC is currently developing guidance on the expanded definition of designated services, particularly for established practitioners who have provided professional services ¬¬for many years to established clients.

Simplified customer due diligence may be undertaken in certain low risk circumstances as part of initial and ongoing customer due diligence.

CPA Australia resources

CPA Australia will continue to provide updates and resources in the lead up to the start date. These will include enhanced website resources; a webinar dedicated to the new obligations; and regular InPractice updates. This will complement and expand on the resources provided by AUSTRAC.

Neville Birthisel is a regulations and standards adviser at CPA Australia