AML Laws For Accountants And Business Advisers: What To Prepare For Before 2026

Accountants and business advisers often play a key role in helping clients set up companies, establish trusts, manage business structures and navigate significant transactions. Under Australia’s anti-money laundering and counter-terrorism financing reforms, some accounting and advisory businesses may have new compliance obligations from 1 July 2026 if they provide certain designated services.

For affected firms, the reforms may change how clients are onboarded, what information is collected, how identity and ownership are verified, and how records are kept. They may also require updates to engagement letters, service agreements, privacy documents and internal compliance processes.

Why Do The AML/CTF Reforms Matter For Accountants And Advisers?

Australia’s AML/CTF regime is being expanded, simplified and modernised. The changes are designed to make the regime clearer, more effective and more aligned with international standards.

Money laundering risks do not only arise in banks or financial institutions. Criminals may also try to use professional services to make unlawful funds appear legitimate, particularly where those services involve companies, trusts, business structures, ownership arrangements or significant transactions.

Accountants and business advisers can be exposed to these risks because they often help clients organise financial affairs, create legal structures and manage business records. In some cases, those services can affect who owns, controls or benefits from assets. This is why the reforms focus on the type of service being provided, not just the professional title of the business.

Are Accountants And Business Advisers Covered By The New AML/CTF Laws?

Some accountants, bookkeepers, tax agents and business advisers may be covered by the new laws, but not simply because they work in accounting or advisory services. The key question is whether the business provides a designated service under the AML/CTF regime.

This distinction matters. A firm providing routine bookkeeping or basic tax compliance may have a different risk profile from a firm helping clients establish companies, create trusts, assist with nominee arrangements, provide certain registered office or corporate administration services, or support transactions involving ownership or control of assets.

In other words, accounting and advisory firms should assess their actual services, client base and transaction types rather than assuming they are automatically captured or completely exempt.

What Accounting And Advisory Services Could Be Affected?

The reforms may be relevant where accounting or advisory businesses provide services connected with company formation, trust establishment, business structuring, nominee arrangements, corporate administration or beneficial ownership arrangements.

For example, a business that helps clients create a company or trust may need to consider whether that service falls within the new AML/CTF framework. Similarly, an adviser who assists with business sales, ownership changes or complex corporate structures may need to assess whether the service creates AML/CTF obligations.

The important point is that AML/CTF obligations are tied to regulated services, not job titles. This means the same accounting firm may need to assess different service lines separately, because some activities may be more likely to fall within the AML/CTF regime than others.

When Do The New Obligations Start?

For newly regulated Tranche 2 businesses, AML/CTF obligations generally begin from 1 July 2026. These entities can enrol with AUSTRAC from 31 March 2026, giving them time to understand and prepare for their new obligations.

This timing is important because AML/CTF compliance usually cannot be addressed by a single document update at the last minute. Accounting and advisory firms may need time to review their services, update client onboarding processes, train staff, prepare internal procedures and seek specialist legal support where needed.

What Obligations Could Apply?

If an accounting or advisory business is captured, it may need to comply with a range of AML/CTF obligations. These may include customer due diligence, client identity verification, beneficial ownership checks, risk assessments, suspicious matter reporting, record keeping, staff training and ongoing monitoring.

A captured business may also need an AML/CTF program. This is a documented framework that sets out how the business identifies, manages and reduces money laundering and terrorism financing risks. The program should be proportionate to the firm’s services, client base, size and risk profile.

In practice, customer due diligence generally means knowing who the client is, verifying relevant information, and understanding who ultimately owns or controls a company, trust or other structure. For higher-risk clients or transactions, this may involve asking further questions about the purpose of the work, the source of funds or the source of wealth.

How Could Client Onboarding Change?

Client onboarding may be one of the most visible changes for affected accounting and advisory firms. A firm may need to collect more information before starting work, particularly where the client is a company, trust, overseas client or part of a more complex ownership structure.

This could include requesting identity documents, company details, trust information, beneficial ownership information and, in higher-risk cases, further information about the purpose of the work or source of funds. Firms may also need a process for deciding when to ask follow-up questions, delay work, escalate a concern internally or decline to act.

This can affect the client experience. Clients may be asked for more information than they are used to providing, and some work may not be able to begin until verification steps are complete. For this reason, firms should make sure their onboarding forms, engagement terms and privacy documents clearly explain why information is being collected and what happens if it is not provided.

Why Engagement Terms, Privacy Documents And Service Agreements May Need Updating

For affected firms, legal documents may need to support the new onboarding and compliance processes. Engagement letters and service agreements may need to explain that the firm can request identity documents, company information, trust information or other details before providing services.

They may also need to address what happens if a client does not provide the required information. For example, the firm may need the right to delay work, suspend services, decline to act or terminate an engagement if AML/CTF concerns arise.

Privacy documents may also need review. Accounting firms already handle sensitive financial and personal information, and AML/CTF compliance may increase the amount of information collected. This could include identity documents, ownership details, company information, trust information and other records used to verify clients.

Clients should understand why information is being collected, how it will be used, how it will be stored and when it may be disclosed for legal or regulatory reasons. Clear privacy policies and collection notices can help manage this process.

Legal documents will not replace a full operational AML/CTF program where one is required. However, they can help support compliance by setting expectations with clients and giving the firm clearer processes for requesting information, managing delays and handling regulatory obligations.

Are The Risks Different For Bookkeepers, Tax Agents And Business Advisers?

Yes. Different accounting and advisory businesses may have different risk profiles depending on what they do.

A bookkeeper that only processes routine financial records may have a different AML/CTF risk profile from an adviser who helps clients establish companies or trusts. A tax agent that only prepares standard tax returns may be different from a firm that provides business structuring advice, assists with ownership changes or supports larger transactions.

This distinction is important. The reforms should not be presented as applying equally to every accountant, bookkeeper, tax agent or adviser. Instead, firms should look closely at their services and consider whether any of their work involves designated services under the AML/CTF regime.

What Should Accounting And Advisory Firms Do Now?

Accounting and advisory firms should begin by mapping their services against the AML/CTF reforms. In particular, they should identify whether they provide services connected with company formation, trust establishment, nominee arrangements, corporate administration, beneficial ownership or higher-risk transactions.

Once your firm understands whether it may be captured, review the client onboarding process, engagement terms, privacy documents and internal compliance workflows. Firms may also need to consider staff training and specialist AML support, particularly if they need to prepare a full AML/CTF program or risk assessment. 

A practical preparation process may include reviewing the services your firm provides, identifying any higher-risk work, checking what client information you currently collect, updating engagement letters and service agreements, reviewing privacy policies and collection notices, training staff on AML/CTF red flags and considering whether specialist AML support is required.

FAQs

Do AML laws apply to accountants in Australia?

Some accountants may be regulated if they provide certain designated services. The rules apply based on the services provided, not simply because a business is an accounting firm.

Are bookkeepers covered by AML/CTF laws?

Bookkeepers may need to review whether their specific services are captured. Routine bookkeeping may have a different risk profile from services involving company structures, trusts, nominee arrangements or transactions.

What accounting services may be captured?

Services connected with company formation, trust establishment, nominee arrangements, corporate administration, beneficial ownership structures and certain transactions may be more likely to require review.

Do accountants need to verify client identity?

If an accounting or advisory firm is captured by the AML/CTF regime, customer due diligence and identity verification obligations may apply. This may include verifying a client’s identity and understanding who owns or controls a company or trust.

Should accounting firms update their engagement letters?

Affected firms should consider updating engagement letters to cover identity checks, requests for information, delays, privacy, regulatory reporting and suspension or termination rights.

What privacy documents should accounting firms review?

Accounting firms may need to review privacy policies, collection notices and onboarding forms to explain how client information is collected, used, stored and disclosed for AML/CTF compliance.

Do accounting firms need specialist AML advice?

Some firms may need specialist AML advice, particularly if they are required to design a full AML/CTF program, conduct a risk assessment or implement operational compliance processes. Legal support can assist with client-facing documents and privacy terms, but this may not replace specialist AML implementation advice.

Need Help Updating Your Documents For The AML/CTF Reforms?

If your accounting or advisory firm may be affected by the AML/CTF reforms, it’s a good idea to start reviewing your client-facing documents and onboarding processes early.

Need help updating your accounting firm’s engagement terms, privacy documents or onboarding forms for the AML/CTF reforms? You can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no-obligations chat.