New AML/CTF Compliance Rules for Accountants in Australia – Effective July 2026
Based on the proposed Anti-Money Laundering and Counter-Terrorism Financing Rules 2024 (AML/CTF Rules) in Australia, accountants who provide designated services under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) are considered reporting entities and must comply with the relevant AML/CTF obligations.
Below is a summary of the key requirements that would apply to accountants in Australia based on the document:
1. Enrolment and Registration (New wef July 2026)
- Accountants must enrol with AUSTRAC if they provide designated services.
- Registration requirements may apply depending on the specific services offered.
2. AML/CTF Program (New wef July 2026)
- Accountants must develop and maintain an AML/CTF program that includes:
- Risk Assessment: Conduct a money laundering/terrorism financing (ML/TF) risk assessment.
- Policies and Procedures: Establish AML/CTF policies to manage and mitigate risks.
- Compliance Officer: Appoint an AML/CTF compliance officer who is a fit and proper person.
- Training: Provide training to staff on AML/CTF obligations.
- Independent Evaluation: Conduct independent evaluations of the AML/CTF program.
3. Customer Due Diligence (CDD): Like POI for KYC purpose as per TPB (PN) 5/2022: TrustEasy can help
- Initial CDD: Accountants must verify the identity of customers before providing designated services. This includes:
- Collecting and verifying customer information (e.g., name, date of birth, address).
- Identifying beneficial owners and persons acting on behalf of the customer.
- Enhanced CDD: Apply enhanced due diligence for high-risk customers, such as politically exposed persons (PEPs) or customers with complex structures.
- Ongoing CDD: Monitor customer transactions and update customer information regularly.
4. Politically Exposed Persons (PEPs)
- Accountants must identify and conduct enhanced due diligence for customers who are PEPs or have high ML/TF risks.
- Obtain senior management approval before providing services to PEPs.
5. Suspicious Matter Reporting (New wef July 2026)
- Accountants must report suspicious matters to AUSTRAC if they suspect money laundering, terrorism financing, or other serious crimes.
- Reports must be submitted within 24 hours of forming a suspicion.
6. Threshold Transaction Reporting (New wef July 2026)
- Accountants must report cash transactions of AUD 10,000 or more (or foreign currency equivalent) to AUSTRAC.
7. Record-keeping (Already in place)
- Maintain records of customer identification, transactions, and AML/CTF compliance activities for at least 7 years.
8. Reliance on Third Parties
- Accountants may rely on third parties to conduct customer due diligence, but they must ensure the third party complies with AML/CTF requirements and that they can access the information upon request.
9. Correspondent Banking Relationships (New wef July 2026)
- If accountants engage in correspondent banking relationships, they must conduct due diligence on the respondent financial institution and assess ML/TF risks.
10. Transfers of Value (New wef July 2026)
- Accountants involved in transfers of value (e.g., international funds transfers) must comply with obligations to collect, verify, and pass on payer and payee information.
11. Cross-Border Movement Reporting (New wef July 2026)
- Accountants must report the movement of monetary instruments (e.g., cash, cheques) of AUD 10,000 or more into or out of Australia.
12. Secrecy and Access (New wef July 2026)
- Accountants must ensure the confidentiality of AUSTRAC information and only disclose it to authorized entities.
13. Compliance Reports (New wef July 2026)
- Submit annual AML/CTF compliance reports to AUSTRAC.
14. Exemptions and Special Cases (New wef July 2026)
- Accountants may be exempt from certain CDD requirements in specific circumstances, such as delayed verification for low-risk customers or services provided in foreign countries.
15. Training and Awareness (New wef July 2026)
- Ensure all staff are trained on AML/CTF obligations, including identifying suspicious activities and understanding reporting requirements.
16. Independent Evaluations (New wef July 2026)
- Conduct regular independent evaluations of the AML/CTF program to ensure compliance with the Act and Rules.
17. Keep Open Notices (New wef July 2026)
- If issued a “keep open notice” by law enforcement, accountants must keep an account open for investigative purposes, even if they would otherwise close it due to suspicious activity.
18. Reporting Group Obligations (New wef July 2026)
- If part of a reporting group, ensure that the lead entity complies with AML/CTF obligations on behalf of the group.
19. Transitional Provisions (New wef July 2026)
- Accountants must comply with transitional provisions if they were previously exempt from certain AML/CTF obligations.
20. Forms and Documentation (New wef July 2026)
- Use prescribed forms for reporting, such as suspicious matter reports, and threshold transaction reports, and keep open notices.
Summary:
Accountants in Australia who provide designated services under the AML/CTF Act must comply with a comprehensive set of AML/CTF obligations, including customer due diligence, reporting suspicious matters, maintaining records, and ensuring staff are trained. They must also develop and implement an AML/CTF program tailored to their business’s ML/TF risks.
The exposure draft provides detailed rules on how these obligations should be met, and accountants must ensure they are fully compliant with the final rules once they are enacted next year wef July 2026. TrustEasy is considering incorporating these proposed rules in trust accounting software for Accounting Firms to stay compliant. It already has integration with Xero Practice Manager (XPM) and Access Practice Manager (APM) to make the transition easier.
Also If you need a reliable solution for managing trust accounts? Build Trust offers comprehensive services to ensure compliance with AML/CTF rules.
