AUSTRAC Obligations for Australian Accountants: What You Must Do Before 1 July 2026
From 1 July 2026, Australian accountants, registered tax agents, BAS agents and auditors must enrol with AUSTRAC and implement a full AML/CTF compliance program.
Accountants are now AUSTRAC reporting entities
For the first time, Australian accounting professionals must enrol with AUSTRAC and comply with the AML/CTF Act 2006 (as amended 2024). In scope: registered tax agents, BAS agents, external auditors, insolvency practitioners, management consultants who manage client funds or form entities. The trigger is the **designated services** you provide — not your professional title.
Step 1 — Enrol with AUSTRAC
Every accounting firm providing designated services must enrol via AUSTRAC Online before providing those services. Required: business name and ABN, principal address, compliance officer contact details, designated services list. Enrolment is free. Failure to enrol: up to **A$19,000/day** civil penalty.
Step 2 — Appoint a Compliance Officer
Your AML/CTF Program must designate a senior person as Compliance Officer, responsible for: - Day-to-day AML/CTF oversight - Staff training - Annual program review - SMR escalation decisions A senior partner or principal can hold this position — it need not be a dedicated role.
Step 3 — Develop your written AML/CTF Program
**Part A — Risk-based framework**: Your ML/TF risk assessment, policies and controls for high-risk clients. **Part B — KYC/CDD procedures**: How you verify identities, beneficial ownership, source of funds, and when EDD applies. Must be approved by senior management and independently reviewed at least every 3 years.
Step 4 — Conduct CDD for every client
**Individuals**: Full name, DOB, address + government-issued photo ID verification. **Companies**: Company name, ACN, directors, and all UBOs with 25%+ ownership. **Trusts**: Trustee details, settlor, beneficiaries, trust deed. Apply **Enhanced Due Diligence** for PEPs, high-risk countries, and complex structures. Retain all CDD records for **7 years**.
Step 5 — File SMRs when required
File with AUSTRAC within 24 hours (terrorism suspicion) or 3 business days (other suspicion) when you suspect a transaction involves proceeds of crime, money laundering, or tax evasion linked to financial crime. **Tipping-off prohibition**: You cannot tell the client you have filed or are considering filing an SMR. Criminal penalties apply for breach.
Step 6 — Maintain 7-year records
Retain for 7 years: all KYC/CDD documents, transaction records, SMR-related records (including non-filing decisions), staff training records, and AML/CTF program versions. Complylty automatically enforces 7-year retention locks and alerts you 90 days before document expiry.