Compliance · Accounting & bookkeeping

AML/CTF Tranche 2 for accountants and bookkeepers

Live since 1 July 2026. If your firm provides a designated service, you now carry bank-grade customer due diligence, ongoing monitoring and seven-year records.

Live from
1 July 2026
Instrument
Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), as amended by the AML/CTF Amendment Act 2024 and the AML/CTF Rules 2025
Who it captures
Firms providing a designated service: managing client money, accounts, securities or assets; forming, operating or managing companies and trusts; acting as registered office, nominee, director or trustee. Belonging to the profession is not enough; the firm must provide the service. No turnover or headcount exemption.
Penalty
Civil penalties reach 100,000 penalty units: $36.4 million per contravention for a corporation.
What recurs

Every one of these has a due date. Missing one is not a judgement call — it is a diary problem.

  • 3 business daysSuspicious matter report
  • 24 hoursTerrorism financing report
  • Per $10k+ transactionThreshold transaction report
  • AnnuallyCompliance report
  • 7 yearsRecord retention

What has to happen, repeatedly

  • Enrol with AUSTRAC and keep enrolment particulars current
  • Appoint an AML/CTF compliance officer
  • Maintain an enterprise-wide risk assessment and a written AML/CTF program
  • Initial customer due diligence and beneficial-owner checks on every client
  • Risk-rate each customer, and apply enhanced due diligence where required
  • Monitor transactions and customer behaviour on an ongoing basis
  • Submit suspicious matter reports within 3 business days, or 24 hours for terrorism financing
  • Report cash transactions of $10,000 or more
  • Screen and train staff, and independently evaluate the program at intervals
  • File an annual compliance report

What you would have to produce

  • The AML/CTF program and every version of it
  • Customer identification and beneficial-owner records
  • Risk ratings and the reasoning behind them
  • Ongoing monitoring output and the decisions taken on it
  • Staff training records
  • All of it retained for seven years

Start with these, and they’re free

  • Set up a client-onboarding checklist in the practice software you already run, so the CDD steps cannot be skipped
  • Turn on document auto-filing by client, so verification records land in the right place without anyone naming a file
  • Create a saved search or view for clients whose risk rating has not been reviewed this year
This is general information about an obligation, not legal advice. Whether it applies to your firm, and how, is a question for your lawyer or your professional body.

Last reviewed 2026-09-07

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