Financial crime costs Australia an estimated A$60 billion a year, with more than A$12 billion tied to drug-related laundering alone — and the accounting sector's access to client funds and entity structures has made it a specific target. Under the AML/CTF Amendment Act 2024, accounting firms providing designated services are now operating as AUSTRAC reporting entities.
How do criminals actually exploit the accounting industry?
Not just through complicit accountants — criminal groups that use accountants as facilitators move higher sums and cause roughly 2.5 times more crime-related harm than groups operating without that kind of professional support, according to figures cited in AUSTRAC's own risk analysis. Beyond the direct laundering exposure, a FATF grey-listing can decrease foreign investment by around 3% of GDP — a reminder that weak sector-wide controls carry consequences well beyond any individual firm's own risk.
Which accounting services actually bring a firm into scope?
Five categories of designated service, set out in AUSTRAC's professional designated services table: real property transactions (buying, selling, leasing, or transferring on a client's behalf); asset management, including client funds, securities, and trust accounts; entity creation and management, covering trusts, corporations, and other legal entities; facilitating financial transactions such as mergers, acquisitions, or business sales; and legal arrangement services, including acting as a nominee director or shareholder.
What do the new requirements actually involve?
A documented money-laundering/terrorism-financing risk assessment specific to the firm. Customer due diligence procedures. Transaction monitoring capable of flagging genuinely unusual activity. Suspicious matter reporting to AUSTRAC. A firm-specific AML/CTF programme, not a generic template. Independent evaluation of that programme every three years — or every two years for firms assessed as higher-risk. And seven-year record retention across all of it.
When did this actually take effect?
AUSTRAC enrolment was required by 31 March 2026, with full compliance required from 1 July 2026 — both dates have now passed. For accounting firms providing designated services, this is no longer a forthcoming obligation to prepare for; it's the operating standard AUSTRAC now expects to see in place. See MemberCheck's accounting industry page for how due diligence and screening apply to accounting practice specifically, and building a risk-based AML programme for Tranche 2 for how to structure the programme itself.
