Scope

A reporting entity is any person providing designated services. For accounting practices, you are a reporting entity if you provide one or more of the professional services designated in section 6, Table 6 – Professional Services of the AML/CFT Act.

These services are outlined in our Q&A on Australia’s regime. 

Obligations

• Build an AML/CTF program which includes a risk assessment, updated and new policies and processes and a training schedule.
• Start with conducting a risk assessment of your practice to identify and assess the risk of your practice being misused for money laundering and terrorism financing (ML/TF).
• Establish your governance structure. Appoint the governing body, compliance officer and senior manager(s). For smaller practices, multiple roles may be held by the same individual.
• Before 1 July 2026, enrol with AUSTRAC: a two-step process. 1) open an account, 2) complete an application to enrol form.
• Update, and develop new, policies and procedures to mitigate the specific risks you identified in your risk assessment. 
• Put in place a training schedule for yourself and your employees, appropriate to their role, to learn the indicators of criminal activity and the action to take.
• Report to AUSTRAC suspicious activities and when you transfer $10,000 or more in physical currency.
• Submit to AUSTRAC your annual compliance report. Due in the first quarter of a new financial year for the immediate past financial year.
• Review your risk assessment and AML/CTF program if your practice makes changes, such as offering a new designated service, or new threats emerge.
• Engage an external party to evaluate the effectiveness of your AML/CTF program at least once every three years.

Risk assessment

AUSTRAC’s Money Laundering in Australia Risk Assessment, 2024, rated accountants as posing a high and stable money laundering vulnerability. This reflects that they are central to the financial system and their professional services are desired by criminals.

Australia is a member of Financial Action Task Force (FATF). FATF leads global action to tackle money laundering, terrorist and proliferation financing with 40 recommendations to implement an effective regime.

FATF’s last mutual evaluation of Australia’s regime was in 2015 and concluded that Australia has a mature regime but that certain key areas remain unaddressed. Its latest follow up assessment in 2024, found Australia had made progress in addressing some deficiencies. FATF is scheduled to be onsite to undertake its next mutual evaluation during November 2026.