AML/CTF

Is Your Accounting Firm Ready for AML/CTF Tranche 2?

Here is the hard truth: from 1 July 2026, your accounting firm is a regulated entity under Australia’s Anti-Money Laundering and Counter-Terrorism Financing laws.

Not “might be.” Not “if you do certain types of work.” Not “only if AUSTRAC comes knocking.”

If your firm provides designated services, and the majority of Australian accounting firms do, you are in scope. The obligation is not optional, and it is not negotiable.

The question is not whether your firm needs to act. The question is whether your firm is actually ready.

For most firms, the honest answer is no.

What AUSTRAC actually expects

AUSTRAC has been publicly clear about its expectations for newly regulated entities. It does not expect perfection on day one. What it does expect is genuine, proactive effort to understand and manage money laundering and terrorism financing risk.

That is a deliberately high standard, and it is worth understanding precisely what it means in practice.

Genuine effort means a written AML/CTF program that reflects how your firm actually operates, not a template downloaded from a government website with your firm’s name on the cover. It means a nominated AML/CTF Compliance Officer who is actively performing the role, not simply holding the title. It means customer due diligence processes that are consistently followed across every designated service engagement, not improvised on a case-by-case basis.

It means staff who can demonstrate they understand their obligations, with assessed training, documented evidence, and a register that shows who was trained, when, and to what standard.

And it means an ongoing monitoring system that identifies changes in client relationships and flags concerns in real time, not an annual check conducted by whoever happens to remember.

The five gaps most firms have right now

Based on what we are seeing across the profession, most accounting firms currently have at least one, and often all, of the following gaps.

• No written AML/CTF program. Or a draft that has never been approved by the partners. A program that is not approved by senior management does not satisfy AUSTRAC’s requirements. Approval is not administrative; it is a leadership obligation.
• No operational AML/CTF Compliance Officer. Many firms have nominated someone, but the role is not yet functional. The AML/CTF Compliance Officer must have genuine authority, genuine competence, and genuine responsibility for the program. A name on a form is not enough.
• No consistent CDD workflow. Customer due diligence is being applied inconsistently, sometimes thoroughly, sometimes not at all, depending on which partner or manager is running the engagement. Inconsistency is not a minor operational issue. It is a systemic compliance failure.
• No training evidence. A team meeting or a conversation is not training evidence. AUSTRAC expects a documented training register showing who completed which modules, when, and with what assessed outcome. If it is not documented, it did not happen.
• No monitoring system. Ongoing monitoring is not a once-a-year review. It is an event-driven and periodic system that triggers a compliance review whenever material changes occur in a client relationship. Most firms do not have this in place at all.

The consequence of waiting

AUSTRAC does not accept a program that sits on a shelf. It does not accept a compliance officer in name only. It does not accept a firm that treats this as a tickbox exercise completed the week before the deadline.

The firms that demonstrate genuine, proactive effort from 1 July 2026 are the firms that have built their systems, trained their staff, documented their decisions, and can show AUSTRAC an audit-ready evidence trail on demand.

The firms that have not done this will be in the position of explaining to a regulator why they chose not to prioritise their legal obligations.

That is not a conversation any firm principal wants to have.

The time to act is now

The firms that are ahead of this are not the largest firms or the best-resourced firms. They are the firms whose leadership recognised early that this was a genuine operational obligation, not a compliance exercise, and took structured, deliberate action.

There is still time to get this right. But the window is closing.

1 July 2026 is not a soft deadline. It is the date on which your obligations are fully in force and your exposure becomes real.

The question your firm needs to answer today is not “do we need to act?” The answer to that question is yes.

The question is “how quickly can we get operational?”

This article is general guidance only and does not constitute legal advice. Firms should confirm their specific obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and seek independent legal advice where required.

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