Quiz: How much do you know about money laundering?

The article is relevant to members in Australia and was current at the time of publication.

1. Which of the following services may make an accounting practice a Tranche 2 reporting entity? [HINT: there is more than one correct answer]

1. Providing your address as the registered address of your corporate clients
2. Offering general business advice
3. Managing client money, forming companies/trusts, structuring transactions
4. Providing tax-only services
5. Compiling financial statements

2. What should accounting firms do now to get ready for Tranche 2?

1. Wait for final AUSTRAC rules
2. Outsource all AML tasks
3. Determine if they are providing “designated services”
4. Notify all clients immediately

3. All Tranche 2 accounting firms must enrol with AUSTRAC within what timeframe of providing a designated service?

1. 7 days
2. 14 days
3. 28 days
4. 90 days

4. Which one of the following is NOT part of a compliant AML/CTF Program?

1. Governance and compliance oversight
2. ML/TF/PF risk assessment
3. Documented policies, systems and controls
4. Annual financial reporting audit

5. How often must Tranche 2 entities conduct an independent review of their AML/CTF Program?

1. Every year
2. At least once every three years
3. Only when requested by AUSTRAC
4. Never

6. Under Tranche 2 reforms, when must initial CDD (customer due diligence) be completed?

1. Before issuing an invoice
2. Only for high-risk clients
3. Before providing a designated service
4. After the first 30 days of the business relationship

7. Enhanced Due Diligence (EDD) must be applied to which one of the following?

1. All small business clients
2. New BAS clients
3. High risk clients such as politically exposed persons (PEPs)
4. Anyone with overdue invoices

8. Which of the following is a typical red flag for accountants under AML/CTF risk assessments?

1. A client changing their address
2. Reluctance to provide documents
3. Requests for quarterly reports
4. Clients with multiple email addresses

9. A client insisting on using complex structures without clear commercial justification is an example of:

1. Normal tax planning
2. A potential ML/TF red flag
3. Poor administration
4. Overlooking compliance issues

Scoring Guide

• 9 correct: Your practice is on track for July 2026 readiness
• 7–8 correct: Moderately prepared — refine your AML/CTF Program and training
• 4–6 correct: Significant gaps — begin structured preparation immediately
• 0–3 correct: High compliance risk — urgent action required