Which accounting services are AML/CTF designated services?
The new AML/CTF rules for accountants are service based. The fact that a business is an accounting firm does not, by itself, answer whether it is regulated.
The practical question is: what does the firm actually do for clients?
From 1 July 2026, specified professional services can be designated services under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. If an accounting firm provides one of those services with the required geographical link to Australia, AML/CTF obligations may apply.
This page is a practical guide to identifying the types of accounting work that need closer attention. It does not replace AUSTRAC's detailed guidance, which should be checked against the facts of each service.
Published 23 August 2026. Last reviewed 23 August 2026. Technically reviewed by the Taxpartna tax team.
The nine professional designated service areas
AUSTRAC groups the newly regulated professional services into nine broad areas.
1. Assisting with a real estate transaction
This can include assisting in the planning or execution of a transaction to buy, sell or transfer real estate.
For an accounting firm, the important distinction is between providing ordinary tax advice about a possible property transaction and becoming sufficiently involved in the planning or execution of the transaction itself.
Examples that may require closer review include a firm coordinating transaction steps, preparing transaction documentation as part of the deal process or acting for a client in a way that directly advances the transaction.
2. Assisting with the sale, purchase or transfer of a company or legal arrangement
This category can be relevant to business acquisitions, disposals and ownership changes.
An accountant who gives tax advice about the consequences of a possible business sale is not necessarily providing the designated service at that point. AUSTRAC's guidance draws a distinction between advice that informs a decision and activity that directly advances a transaction that is in progress or proposed.
Once the firm is instructed to assist with the actual sale or transfer, the analysis can change.
3. Receiving, holding, controlling or managing another person's property for a transaction
This is an important area for accounting firms that receive client money or other property and then control how it is applied.
AUSTRAC gives an example of an accounting practice receiving money into its own account and paying expenses for a client. In that situation, the practice may be receiving, holding and controlling the client's money and providing a designated service.
Normal bookkeeping entries are different from taking possession or control of the client's property.
Firms that operate trust accounts, clearing accounts or informal client money arrangements should examine this area carefully.
4. Assisting with equity or debt financing
This category deals with organising, planning or executing equity or debt financing involving a body corporate or legal arrangement.
Potential accounting examples include more active involvement in arranging a funding transaction, structuring an equity subscription or coordinating debt financing for a company or trust.
Providing a set of financial statements to a bank does not automatically mean the firm is providing the designated service. The question is the nature of the assistance and whether it falls within the regulated transaction activity.
5. Selling or transferring a shelf company
A business that sells or transfers a shelf company can provide a designated service.
This may be less common in ordinary suburban accounting practices than company incorporation, but firms that maintain companies for later transfer need to address it directly in their service mapping.
6. Creating or restructuring a body corporate or legal arrangement
This is likely to be one of the most relevant categories for accountants.
It can include assisting with the creation or restructuring of companies, trusts and other legal arrangements.
Examples that warrant review include:
- setting up a company as part of a client structure
- establishing a discretionary trust or unit trust
- preparing or coordinating the steps to restructure an existing group
- assisting with changes that alter the legal ownership or control structure
AUSTRAC's guidance makes it clear that the analysis can extend beyond physically lodging a form. Advice may be caught where it is comprehensive enough to allow the client to create the structure without further professional assistance.
This is why firms should map the actual work performed, not simply who presses the final lodgement button.
7. Acting in specified positions
Certain services involving acting for a client in a position connected with a body corporate or legal arrangement are designated services.
Firms should review whether they or related service entities act in positions such as nominee or other specified roles covered by the legislation.
The exact position and context matter, so this area should be checked directly against AUSTRAC's current guidance.
8. Arranging for another person to act in specified positions
A firm can also be caught where it arranges for another person to act in a relevant position.
This is particularly relevant to corporate services businesses that maintain a network of nominee or officeholder arrangements rather than accounting firms that simply introduce a client to an independent professional.
Again, the legislative wording and the actual service should be checked.
9. Providing a registered office or principal place of business address
Providing an address for a company or legal arrangement can be a designated service in specified circumstances.
Many accounting firms allow client companies to use the firm's office as the registered office. This should not be treated as a minor administrative detail without checking the new rules.
A firm should identify how many clients use its address, what service is actually provided and whether an exemption or other qualification applies.
What about ordinary tax advice?
One of the most useful distinctions in AUSTRAC's professional services guidance is between advice and activity that directly advances a regulated transaction.
An accountant may advise a client about the tax consequences of selling a company without yet being involved in a transaction. That is different from being instructed to help execute a sale to an identified buyer.
Likewise, explaining the tax differences between a company and a trust is not necessarily the same as actually creating the chosen structure or giving instructions that are sufficient for its creation.
The line will depend on the facts. Firms should avoid broad internal rules such as "tax advice is never caught" or "all restructuring advice is caught". Those shortcuts can be misleading.
A practical service mapping exercise
For most accounting firms, the easiest way to work out their position is to build a service register.
For each service line, record:
| Service | Do we provide it? | Could it be designated? | Who provides it? | What process applies? |
|---|---|---|---|---|
| Annual tax compliance | Yes/No | Review | Team | Existing tax process |
| Company establishment | Yes/No | Likely area to review | Team | AML assessment |
| Trust establishment | Yes/No | Likely area to review | Team | AML assessment |
| Business sale assistance | Yes/No | Depends on involvement | Partner | AML assessment |
| Restructuring | Yes/No | Depends on scope | Partner | AML assessment |
| Registered office service | Yes/No | Review | Admin | AML assessment |
| Client money handling | Yes/No | High priority to review | Partner/Admin | AML assessment |
The point of the exercise is to find the actual regulated activity inside the firm's normal service descriptions.
Do not forget group entities
Some accounting groups provide corporate secretarial services, registered office services or trust establishment through a separate company.
The AML/CTF analysis should be done at the level of the entity that actually provides the designated service. A group-wide policy may still be sensible, but enrolment and legal responsibility need to be considered for the correct entity.
Geographical link and exemptions still matter
Identifying a service that looks like a designated service is not always the final step.
The legislation includes geographical link requirements, exemptions and detailed qualifications. AUSTRAC's examples are useful, but they do not cover every arrangement.
Where a firm's service sits close to the boundary, document the analysis and obtain advice rather than relying on a broad assumption.
Where Taxpartna fits
Taxpartna can support AML/KYC screening and help organise information relevant to a firm's customer risk assessment.
It does not determine whether the firm is providing a designated service. That decision requires the firm to understand the scope of its engagement and compare the work actually performed with the legislation and AUSTRAC guidance.
A good implementation therefore has two separate controls:
- 1a service-level process that identifies whether AML/CTF applies to the engagement; and
- 2a customer-level process that completes the required due diligence and risk assessment where it does.
Taxpartna can assist with the second process. The firm remains responsible for both. Our customer due diligence checklist for accounting firms walks through that customer-level process, and AML/KYC vs TPB client verification explains how it differs from tax practitioner checks.
Authoritative sources
Whether a service is a designated service depends on the legislation and AUSTRAC guidance. The following primary sources should be checked when this page is technically reviewed or materially updated.
- AUSTRAC - Professional designated services
- AUSTRAC - Accountants
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
Frequently asked questions
Not by itself. The firm should identify whether it provides one of the professional designated services. Additional services around structures, transactions, client money or registered office arrangements may be relevant. See our AML/CTF obligations guide for accountants.
Important information. This page provides general information only and is not legal advice. Whether a service is a designated service depends on the legislation and the facts of the engagement. Firms should use AUSTRAC's current guidance and obtain advice for borderline or complex arrangements. Taxpartna is a quality assurance assistance platform. It does not provide legal advice, tax agent services or AML/CTF compliance certification.