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AML Compliance for Australia’s Accounting Sector

AML Compliance for Australia’s Accounting Sector

#Tranche 2 Reforms, #AML/CTF Amendment Act 2024

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June 24, 2025
3 Minutes

Introduction

Australia's accounting sector is undergoing a big legislative upheaval. Under the AML/CTF Amendment Act 2024, accountants will soon be obliged to meet strict anti-money laundering requirements. Professionals in this area must understand their new responsibilities and create a comprehensive, risk-based AML program.

Financial crime costs Australia an estimated~A$60 billion annually, over $12 billion tied to drug-related laundering, with additional harms like human trafficking and cybercrime. Extending AML responsibilities to Tranche 2 entities, including accountants, helps plug intelligence gaps and bolster enforcement across serious organised crime operations.

AML Risks in Australia’s Accounting Sector

According to AUSTRAC's 2024 National Risk Assessment, accounting professionals have a ‘high and stable vulnerability’ to money laundering and are frequently identified as facilitators in the layering phase of laundering schemes.

Because of its importance in arranging complex financial transactions and legal entities, the profession is classified as a ‘gatekeeper’ industry, alongside real estate brokers, lawyers, and trust service providers.

Using accountants in criminal groups results in higher sums and 2.5x more crime-related harm compared to groups without such facilitators.

What Is AML/CTF Amendment Act 2024?

The AML/CTF Amendment Act, passed in November 2024, requires accountants who provide certain specified services to register as reporting entities under the AML/CTF framework. These measures align Australia with worldwide standards and prevent potential FATF grey listing by 2026, which could decrease foreign investment by up to ~3% of GDP.

Accountants must enlist with AUSTRAC by March 31, 2026, and complete full compliance by July 1, 2026.

Designated Services Provided by the Accounting Companies

Accountants who perform any of the following identified services must follow AML/CTF rules:

  • buying, selling, leasing, or transferring real property for customers
  • managing client funds, securities, trust accounts, and other assets
  • creating, managing, or advising on trusts, corporations, or other legal entities
  • facilitating financial transactions (such as mergers, acquisitions, and business sales)
  • providing services for legal arrangements, such as nominee director and shareholder services

How Do Criminals Use the Accounting Industry for Money Laundering

Criminals exploit accounting-related services via:

  • false invoicing or dishonest tax filings to conceal illicit funds
  • creating trusts or shell businesses to conceal beneficial ownership
  • misusing customer trust accounts or business structures
  • engaging in foreign restructuring, offshore transfers, or exploitation of cash-intensive firms
  • reluctant or poor KYC (Know Your Customer) and continuous monitoring methods

The New AML Requirements for Australia’s Accounting Sector

Accountants designated as reporting entities must implement:

  • a thorough ML/TF risk assessment that includes consumer, transactional, regional, and business risks
  • Customer Due Diligence (CDD) and expanded due diligence, if applicable
  • transaction monitoring to identify abnormal patterns
  • timely report of suspicious matters to AUSTRAC
  • development of firm-specific AML/CTF programs and policies
  • periodic independent evaluations (every three years, every two years for higher risk) and record retention for at least seven years

Navigate the New Compliance Landscape with Confidence by Partnering with MemberCheck

MemberCheck supports large enterprises in navigating the complexities of Tranche 2compliance. Our advanced screening and verification solutions are designed to adapt to the unique requirements of each organisation, enabling them to effectively identify risks, meet AML/CTF obligations, and stay ahead of regulatory demands. By providing secure, reliable, and easy-to-integrate tools, MemberCheck empowers businesses to strengthen their compliance frameworks and focus on growth while ensuring they remain protected in an evolving regulatory landscape.

FAQs

What are the Tranche 2 Reforms?

The Tranche 2 Reforms are a set of proposed legislative reforms aiming at broadening the scope of Australia's Anti-Money Laundering and Counter-Terrorism Financing laws to include more businesses and professions.

Which industries will be affected by the Tranche 2 Reforms?

The Tranche 2 Reforms will affect real estate agents, precious metals dealers, lawyers, trust and company service providers, and accountants.

Why are the Tranche 2 Reforms necessary?

The Tranche 2 Reforms are required to align with global standards established by the Financial Action Task Force (FATF), which recommends that countries regulate DNFBPs within their AML/CTF frameworks and to strengthen Australia's ability to detect, prevent, and combat money laundering and terrorism financing activities.

What steps should regulated entities take to comply with the Tranche 2 Reforms?

Regulated entities must conduct detailed risk assessments, develop and implement strong AML/CTF programs, ensure that employees receive adequate training on AML/CTF obligations and the entity's compliance program, establish systems for reporting suspicious activities and keeping records in accordance with regulatory requirements.

What is the AML Amendment Act 2024?

The Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Amendment Bill 2024, passed by the Australian Parliament on 29 November 2024, marks a major milestone in Australia’s efforts to combat financial crime.

This legislative reform strengthens the AML/CTF Act 2006 by:

  • expanding the AML/CTF regime to include certain high-risk professions such as lawyers, accountants, real estate agents, trust and company service providers, and dealers in precious metals and stones. These sectors, often referred to as ‘Tranche 2’ entities, were previously outside the scope of AML/CTF obligations.
  • simplifying compliance to make it easier for businesses to understand and meet their AML/CTF responsibilities
  • modernising the regulatory framework to reflect evolving business practices, digital technologies, and sophisticated illicit finance tactics

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