AUSTRAC’s AML/CTF Requirements for Accounting Firms
From 1 July 2026, Traverse Accountants is required to comply with the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (the Act) (AML/CTF) and be registered with the Australian Transactions Reports and Analysis Centre (AUSTRAC).
About the Changes and Reporting Obligations
This legislation is designed to reduce the impact of money laundering and terrorism financing and protect the integrity of Australia’s financial system.
These changes align Traverse with sector-wide regulatory requirements and are being implemented across the accounting profession.
Traverse, like all accounting firms who provide Designated Services must comply with the Act, and reporting obligations of those services.
Designated Services provided as professional services include assisting in the planning or execution of:
- a transaction to sell, buy or transfer real estate
- a transaction to sell, buy or transfer a body corporate (ie: a Company) or legal arrangement
- receiving, holding, controlling or managing a person’s property to help in the planning or execution of a transaction
- organising, planning, or executing a transaction for equity or debt financing relating to a body corporate or legal arrangement
- selling or transferring a shelf company
- the creation or restructuring a body corporate or legal arrangement
- acting, or arranging for someone to act on behalf of a person in particular positions in a body corporate or legal arrangement
- providing a registered office address or principal place of business address of a body corporate or legal arrangement
Whilst not all of Traverse’s services are Designated Services, many are and the range of services included in the Act is very broad.
Designated Services Provided by Traverse Accountants
We have identified that some of the common Designated Services provided by Traverse Accountants include:
- Advisory services relating to changes in ownership of entities or assets (e.g. due diligence, valuations);
- Registered company office or principal place of business-related services;
- Acting as a director, company secretary, trustee, or similar role;
- Acting, or arranging for someone to act on behalf of a person, or facilitating the introduction to particular positions in a body corporate or legal arrangement
- Processing banking transactions on a client’s behalf, although specially not as a remittance service;
- Services in relation to the creation of new structures, company’s, bodies corporate, or other legal arrangements including shelf companies.
Where we provide a designated service to a client, we are required to undertake initial and ongoing customer due diligence.
We have engaged an external provider to assist us in facilitating the relevant customer due diligence we are required to maintain to be able to provide these services.
Such due diligence or compliance will likely include your consent, and provision of any information required to any necessary identity or verifications checks, that may be required for us perform a designated service. For existing clients this may not require any immediate check or verification, however new clients or changes and updates to an existing clients’ circumstances, may trigger the requirement for us to review whether there are required compliance events before we can proceed with those designated services.
Our staff are required to undertake AML/CTF training and to monitor and report any suspicious behaviour that may be identified to our Compliance Officer. The Compliance Officer is responsible for the reporting of suspicious matters to AUSTRAC, and in accordance with the Act the Compliance Officer and Traverse are prohibited from advising clients of this report.
What does this mean for you?
- We may request additional personal information about our clients, their business, or income streams so that we can complete the required customer due diligence.
- These requests may be made directly by Traverse or facilitated using systems that Traverse has licensed from external providers.
- The necessary third-party costs incurred by Traverse in performing customer due diligence may be on-charged to clients. If you have any questions about this, please contact us.
- If you cannot or refuse to provide the required information to undertake the customer due diligence required by the Act, we will not be able to provide the Designated service.
- In the event that you fail a customer due diligence check as a result of conflicting information being received, we will likely require that these conflicting items such as your address on photo ID, or other relevant items as determined by our compliance with the Act, be updated or amended before being able to provide the Designated service.
- Our standard terms and conditions will be updated from 1 July 2026 to reflect our status as an AML/CTF registered entity.
