Profession-specific playbook Current
AML/CTF operating playbook for accounting firms
The trigger is the specific service you provide, not your profession title.
Not every service an accounting firm provides is a designated service under Tranche 2 -- and not every accounting firm is a reporting entity. This playbook sets out how the core AML/CTF obligations apply once a firm is captured. It is general information, not legal or compliance advice.
Action plan
1 Confirm which of your firm's services are AUSTRAC designated services This is a service-by-service question, not a blanket rule for the whole firm.
AUSTRAC's AML/CTF reforms extend obligations to accounting practices that provide specific designated services, not to accounting generally. Before assuming Tranche 2 does or doesn't apply, check each service line -- for example managing or controlling client funds, or assisting with certain financial or company-formation transactions -- against AUSTRAC's own designated services guidance, rather than relying on this playbook's summary alone.
- Review each service line your firm offers against AUSTRAC's designated services guidance
- Don't assume routine accounting or tax-return work is automatically a designated service
- Re-check this whenever your firm adds a new service line
Done when: Your firm's service lines have been checked individually against AUSTRAC's designated services guidance, not assumed
AUSTRAC: your AML/CTF obligations2 Appoint an AML/CTF compliance officer within 28 days of providing a designated service This clock starts from actually providing the service, not from enrolling with AUSTRAC.
Once your firm provides a designated service, AUSTRAC's guidance requires an AML/CTF compliance officer to be appointed within 28 days. Build this into your firm's Tranche 2 readiness plan as a hard deadline, not a background task.
- Appoint an AML/CTF compliance officer within 28 days of first providing a designated service
- Confirm the appointee meets AUSTRAC's eligibility expectations for the role
- Document the appointment date to demonstrate the 28-day window was met
Done when: An AML/CTF compliance officer was appointed within 28 days of the firm first providing a designated service
See the AML/CTF compliance officer deep page3 Complete customer due diligence before starting the designated service CDD comes first -- not alongside the engagement, and not after it's underway.
AUSTRAC's guidance requires initial customer due diligence to be completed before your firm starts providing a designated service to a client, with enhanced due diligence required where the client's money-laundering or terrorism-financing risk is high or in other specified circumstances.
- Complete initial CDD before the designated service starts, not after
- Escalate to enhanced CDD where the client's risk is high or another specified circumstance applies
- Keep evidence of when CDD was completed relative to when the service began
Done when: CDD, escalated to enhanced CDD where required, was completed before the designated service began
See the customer due diligence deep pageDesignated services
Funds handling
Managing or controlling client funds
Where your firm holds, manages, or controls client funds as part of a service, check that service against AUSTRAC's designated services guidance -- this category is a common Tranche 2 trigger point for accounting practices.
Corporate services
Assisting with company formation or structuring
Assisting a client to form a company, or acting in a related governance or nominee capacity, is another service type worth checking specifically against AUSTRAC's guidance rather than assuming it sits outside scope.
Trust accounts
Operating a trust account on a client's behalf
Operating or managing a trust account for a client is a further service worth checking individually, given the fund-control element AUSTRAC's designated services guidance focuses on.