Will my accounting practice be captured by Anti Money Laundering regulation - and when?
Internationally, the professions - accountants and lawyers, have been consistently characterised as “gatekeepers” and “professional enablers” of crime and corruption – remember the Panama Papers?
With the passage of the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 to providers of certain professional services, these ‘Tranche 2” entities – including many accounting practices – will become regulated by Australia’s Anti-Money Laundering regime from 1 July 2026.
The regime is a service-based regime. Whether you need to take notice or not depends on whether your practice provides Designated Services or not. Many services commonly delivered by accounting practices —forming companies or trusts, acting as nominee directors, managing client money in transactions, or providing a registered office or business address services — will be Designated Services.
The Tranche 2 reforms are not limited to the “big end of town” — the regime applies to anyone providing a Designated Service, including small and mid-tier practices, who can facilitate (unwittingly or wittingly), corruption and money-laundering. Being compliant is more than just red tape. It changes how you onboard clients and assess and manage risk.
Early preparation will make it manageable — and protect your practice’s reputation – but it is prudent to think about this as soon as possible. Obligations commence for accountants, lawyers, conveyancers and other professionals on 1 July 2026.
To do now:
Assess whether you provide Designated Services or not (see our article here)
Engage leadership — the AML/CTF obligations carry partner/director accountability and big penalties for non-compliance
Assess and map your services against the Designated Services list.
Perform a risk assessment of your practice.
We can help with all of this – register for a webinar or give our AML/CTF team a call.
Paul Gray
Principal
T 03 5225 5231 | M 0414 195 886
E pgray@ha.legal
Hugo Le Clerc
Senior Associate
T: 03 5225 5213 | M: 0438 089 334
E: hleclerc@ha.legal
