Do the new AUSTRAC laws actually apply to your accounting practice?

If you’ve heard the words “Tranche 2” in the last six months and quietly moved on, you’re not alone. Most accountants have. There’s been a lot of noise, and if you’re anything like the principals we’ve spoken to, your honest reaction has been some version of: “that sounds like a bank problem, not mine.”

It’s not a bank problem. And for most small accounting practices in Australia, it is yours. Here’s what changed, in plain English.

What happened

In December 2024, Australia passed legislation extending its anti-money laundering regime to a new group of professions — including accountants, lawyers, real estate agents, and conveyancers.

These are called “Tranche 2” entities. From 1 July 2026, practices that provide certain services became “reporting entities” under the AML/CTF Act. That means obligations. Real ones.

Does this apply to my practice?

The obligation is triggered by specific services listed under the AML/CTF Act — known as Table 6 designated services. In plain terms, these include:

• Setting up companies or trusts on behalf of clients
• Holding or managing client funds
• Assisting clients with the purchase, sale, or transfer of property
• Acting as a nominee director, shareholder, or trustee
• Providing a registered office address for a client entity
• Administering SMSFs where you hold or manage client funds or assets as part of a transaction

Preparing tax returns alone does not trigger the obligation. But the majority of general accounting practices do at least one of the above for at least some clients — which brings the whole practice into scope.

What does ‘in scope’ actually mean?

It means you are now a “reporting entity” under Australian law. Before you can continue providing designated services, you must:

• Enrol with AUSTRAC: Enrolment opened 31 March 2026. All obligations commenced 1 July 2026. Newly regulated entities have until 29 July 2026 to notify AUSTRAC of their appointed AMLCO, but this does not extend the compliance start date.
• Have a written AML/CTF program in place
• Appoint an AML Compliance Officer
• Verify the identity of new clients before providing designated services
• Train your staff on their AML/CTF obligations
• Report suspicious matters to AUSTRAC when they arise

That last one — staff training — is often the last thing practices get to. It is also the one with the clearest audit trail requirement: AUSTRAC wants documented evidence that your people know what to look for.

What if I’m not sure?

AUSTRAC has a free online eligibility checker at austrac.gov.au that steps you through your services. It takes about five minutes.

If you’re still unsure after that, err on the side of assuming you’re in scope — the consequences of being wrong in that direction are minimal; the consequences of being wrong in the other direction are not.