Overview

If you offer one or more of the professional services designated under Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime it is time to plan, build and implement your AML/CTF program.

The first step is to determine if you offer one or more of the designated professional services. Importantly, it is not how many you offer, if you offer one, you will become a reporting entity.

To find out, read through AUSTRAC’s explanation of how it interprets each professional designated service. This outlines what is captured and provides examples of what is not captured. Importantly, when a service, such as tax advice, tips over into a designated service, implementing that tax advice. 

This project plan outlines some of the key steps you can be doing now ahead of become a reporting entity from 1 July 2026. 

	Nov-Dec 2025		Jan-Mar 2026		Apr-Jun 2026
	Governance		Risk assessment		Enrol
	Client hygiene		Uplift policies		Implement program
	Training		Training		Review effectiveness

November/December 2025: - Check in

Governance structure established, client base cleansed and  AML/CTF training underway..

1. Embed in your existing, or set up, your AML/CTF governance structure

• Identify your compliance officer, governing body and senior management
• This may be the same individual for sole traders, small practices
• Understand key AML/CTF roles and responsibilities
• Update your governance framework to ensure accountability and oversight.
• Undertake personnel due diligence

2. Client hygiene

• Review and remove clients you no longer provide services to.
• Looking back over the last 12 months, take a high level snapshot of:
  1. which services you offered, and which are now designated
  2. the types of client you have; individuals, sole traders, corporate, trusts
  3. where are your clients based: locally, within Australia, countries outside of Australia
  4. how you onboard and service your clients: face-to-face, email, video links.

3. Start training

• Undertake initial training to familiarise yourself and your team with AML/CTF obligations.
• Expand your training record to include your team and record AML/CTF specific training as completed.
  
   

January/March 2026: 

Undertake your risk assessment, uplift policies and procedures, keep training.

Sole practitioners and smaller practices Work through AUSTRAC’s accountant program starter kit. Tailor the Starter Kit with data relevant to your practice. Once complete, this will form the basis of your initial AML/CTF program.

1. Undertake risk assessment

• Conduct a risk assessment to identify potential money laundering and terrorism-financing (ML/TF) risks to your practice.
• Use the starter kit to understand the inherent ML/TF risks in offering accounting services
• Download AUSTRAC’s Risk Assessment tool
  1. Adopt or adapt the risk matrix provided to reflect your practice
  2. Answer YES or NO to each designated service to reflect what you offer
  3. At each section, work through the risk factors noting how you will mitigate the risk
  4. From your high-level snapshot of the last 12 months, note which type of client you are willing to service, how you provide your services and the countries in which you provide your services

2. Uplift Policies and Procedures

• Continue to work through the Starter Kit
• You can choose to tailor the policies provided by AUSTRAC in the Starter Kit, or use them as a guide to update your existing polices
• If you tailor AUSTRAC’s policies, ensure you reference existing systems such as your onboarding form in your practice management system
• If you update existing polices, you will also need to identify those you do not have, such as reporting to AUSTRAC, customise and add those to your policy document 
• Your policies must reflect your risk assessment. For example, if you identified that you would offer services to high-risk clients, your policy must outline how you onboard clients and also high-risk clients
• The next step is to review, update and customise your procedures in the same way
• Ensure you have a record of version control and that each document is approved by the relevant person

3. Continue Training

• Monitor AUSTRAC’s page Education about reforms
  • In March 2026, webinars were focussed on conducting your risk assessment
  • In April 2026, webinars are focussed on customer due diligence: onboarding, enhanced and ongoing
• CA ANZ hosted a Sharing Knowledge Session in April 2026 to work through the accountant program starter kit and how you might embed AML/CTF into your system of quality management. The recording can be found under Sharing Knowledge: Supporting Business, and is called ‘Getting your AML/CTF program started’.
• At CA ANZ’s Audit and Accounting conference in May 2026, we are hosting a session on AML/CTF to hear from AUSTRAC how they will approach monitoring new reporting entities and learnings from the regulator in New Zealand.

April/June 2026: 

Enrol with AUSTRAC, implement your AML/CTF program and review effectiveness.

1. Enrol with AUSTRAC

• Apply to enrol with AUSTRAC  as soon as practicable after 31st March 2026
• A two step process, set up an account with AUSTRAC, then complete an application to enrol
• Find out what information is required at Enol with us
• Maintain a record of your enrolment for compliance
• You will need to update any details that change within 14 days of that change.

2. Implement AML/CTF Program

• Complete your AML/CTF program   and ensure it is accessible for, and understandable by, all staff
• Empower your compliance officer to oversee the implementation of your AML/CTF program.

3. Review Effectiveness before 1 July 2026

• Review if staff are implementing your AML/CTF program effectively.
• Identify areas for improvement and implement necessary changes.
• Schedule regular reviews of your AML/CTF program, at least, annually.

We will let you know when further guidance is published by AUSTRAC, and more resources become available, and update this page.