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AML compliance accountants Australia 2026

AML Compliance for Accountants: What You Need to Know Before 1 July 2026

If your accounting firm creates entities, manages client funds, or provides trust and company services, you may already be in scope.

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Are you affected?

If your accounting firm creates companies or trusts, manages client money tied to transactions, or acts as trustee or director, you are likely a reporting entity and need an AML/CTF program in place by 1 July 2026.

Your obligations

  1. Enrol with AUSTRAC now that enrolment is open
  2. Build an AML/CTF program tailored to your services
  3. Implement customer due diligence procedures
  4. Train staff on red flags and process
  5. Maintain records and reporting readiness
Williams & Associates Chartered Accountants · ABN 12 345 678 901 · Melbourne VIC AML/CTF Risk Assessment — Prepared by Assemble Compliance ASSEMBLE ML/TF RISK ASSESSMENT — CLIENT FILE: JOHN BROWN — AC-RA-001 SECTION 1 — CLIENT DETAILS CLIENT NAME John Michael Brown CLIENT TYPE Individual FILE REF WA-2026-0142 DESIGNATED SERVICE(S) PROVIDED Company formation (Pty Ltd) + SMSF establishment and ongoing management SECTION 2 — ML/TF RISK FACTOR ASSESSMENT RISK FACTOR ASSESSMENT RISK RATING Customer type Australian individual, known locally LOW Service/product type Company formation + SMSF MEDIUM Delivery channel Face-to-face, in-office meetings LOW Foreign jurisdiction No foreign links identified LOW PEP / Sanctions status Not a PEP. No sanctions match. LOW Transaction value / volume SMSF balance ~$850K, company capitalised at $100 MEDIUM Source of funds / wealth Employment income + property equity (verified) LOW OVERALL ML/TF RISK RATING: LOW Standard CDD applies SECTION 3 — ASSESSOR NOTES Client is a long-standing client (8+ years). Standard verification completed. No elevated risk indicators. Assessed by: Sarah Williams, CA Date: 15 April 2026 SAMPLE by Assemble Compliance — assemblecompliance.com.au
Sample risk assessment preview for an accounting practice.

In scope

  • Creating companies, partnerships or trusts for clients
  • Acting as trustee or director for a client
  • Managing client funds for a transaction
  • Corporate restructuring involving transfer of funds
  • Registered office or business address services
  • Trust and company service provider work

Out of scope

  • Tax return preparation
  • Bookkeeping
  • Management accounting
  • Audit services unless fund management is involved
  • Pure tax advisory with no entity creation
  • Financial statement preparation only

The risk of waiting

Waiting compresses everything: scope assessment, drafting, review, training, enrolment admin, and implementation. That is how firms end up rushing the most important part.

How we help

We package the work into a fixed-scope build so your team is not trying to interpret guidance, draft procedures, and pressure-test scope at the same time.

Do accountants have to comply with AML laws?

Accountants are typically captured when they help establish legal entities, operate trusts, provide registered office services, or handle client money linked to designated services.

What accounting services are in scope?

The risk sits around entity formation, trust and company services, and transaction-related fund handling rather than ordinary tax and bookkeeping work.

Can I rely on the AUSTRAC starter kit alone?

The starter kit is a starting point. Most firms still need a tailored program, risk assessment, procedures, and internal rollout documents.

Primary action

Build My Compliance Program

Start with the short form. We review the details, check likely scope, and respond personally with the right next step for your accountants firm.

What happens after you submit?

  1. We review your firm, services, and likely AML/CTF scope.
  2. We identify the fastest path to a compliant program and likely package fit.
  3. You get a personal reply from Assemble Compliance with next steps.

No obligation. No hard sell. We review your firm first and reply personally.


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