Accountants and professional services AML/CTF obligations

When accounting work becomes regulated

Routine bookkeeping, tax return preparation, and standard advisory services are not always designated services. Obligations typically attach when accountants directly help establish companies, trusts, or other legal arrangements, manage client money in transaction contexts, or support arrangements that directly advance high-risk financial outcomes.

Common designated service risk points

• Setting up or restructuring entities where ownership complexity is material
• Acting as a gatekeeper in financing, lending, or transaction execution workflows
• Handling or directing client funds connected to designated services
• Supporting trust/company service provider activities in practice

What firms must have in place

If your services are in scope, your firm needs AUSTRAC enrolment, a risk-based AML/CTF program, a nominated compliance officer, customer due diligence controls, and reporting readiness. Controls should be built around the way accounting teams actually onboard clients, gather documents, assess ownership structures, and escalate unusual activity.

Practical controls that matter

Focus on beneficial ownership verification, source-of-funds challenges for complex matters, clear trigger points for enhanced due diligence, and structured escalation pathways for suspicious patterns. "Paper compliance" is not enough; AUSTRAC expects active use of controls in day-to-day work.