The Critical Distinction: Advising vs. Doing
The most important concept in the Tranche 2 framework for accountants is the line between advising and doing. As AUSTRAC has stated plainly: "It is what you do, not what you are, which is important."
A person's actions must be sufficiently linked to the outcome of the designated service for it to be regulated — which requires the person's assistance to directly advance the relevant transaction. AUSTRAC distinguishes between assisting and merely influencing how the customer proceeds — stating the latter is not sufficient.
Which Table 6 Services Capture Accountants?
Item 1 — Assisting in Real Estate Transactions
If an accountant assists a client in the planning or execution of a transaction to sell, buy, or otherwise transfer real estate — beyond merely advising on the tax implications — they are providing a designated service. This includes structuring a property purchase through a trust or company, or managing funds in connection with the transaction.
Item 2 — Assisting in Business Transfers
Assisting a person in planning or executing a transaction in relation to the buying, selling, or transferring of a business interest triggers a designated service. For accounting practices that advise on and execute business sales, acquisitions, and mergers, this item is directly relevant.
Item 3 — Receiving, Holding, and Managing Client Money
This is one of the most widely applicable items for accounting practices that operate trust accounts. Receiving, holding, controlling or managing property when assisting clients in planning or executing a transaction constitutes a designated service. The item targets holding client money as part of facilitating a third-party transaction, not ordinary professional fee collection.
Item 6 — Assisting with Creation or Restructure of a Company or Trust
This is the item that captures the broadest range of standard accounting services in Australia.
For trusts: The accountant starts providing a designated service once they accept the client's instruction to create the trust and act upon them. Discretionary family trusts, unit trusts, bare trusts, SMSFs — all trust structures created with an accountant's assistance fall within this item.
For companies: Incorporating a company, restructuring its shareholding, converting a sole trader to a corporate structure — these are all designated services.
Item 7 — Acting as Director, Trustee, or Similar
If an accountant (or their firm) acts as a director, company secretary, trustee, or partner of a client entity — or arranges for another person to do so — this is a designated service. Nominee director and trustee services are now regulated.
Item 9 — Providing a Registered Office Address
Providing a registered office or principal place of business address for an entity is a designated service. Many accounting practices provide registered office services as a standard convenience offering. From 1 July 2026, this service alone triggers full Tranche 2 obligations.
The Grey Area CPA Australia Has Publicly Flagged
CPA Australia raised concerns that there was a lack of consistency between AUSTRAC's guidance and the wording of AML/CTF legislation regarding whether some typical accounting services were designated services. Their members' biggest worry: "making sure they stay on the right side of the law."
This grey area is not an excuse for inaction. An accounting practice that has done nothing by 1 July 2026 is not protected by regulatory uncertainty. It is exposed by it. The prudent approach is to map your services methodically, document the analysis, and implement the AML/CTF program the law requires for those services you conclude are captured.
Your Full Obligations as a Tranche 2 Accounting Practice
1. AUSTRAC Enrolment
Practices offering at least one Table 6 designated service must enrol with AUSTRAC. Enrolment is open from 31 March 2026. New reporting entities must be compliant by 1 July 2026. The final enrolment deadline is 29 July 2026.
2. Written AML/CTF Program
Every reporting entity must develop and maintain a written AML/CTF program before providing a designated service. The program must contain a risk assessment and AML/CTF policies tailored to your practice. Generic templates will not satisfy AUSTRAC's expectations.
3. Governance Structure
Your senior management must approve your AML/CTF program. Your governing body must oversee the program and take reasonable steps to ensure compliance. You must appoint an AML/CTF compliance officer and notify AUSTRAC by 29 July 2026.
4. Customer Due Diligence
You must verify identity before providing a designated service — individuals, companies, trusts, and beneficial owners. The obligation to verify arises at the point you commence providing the service, which for most accounting engagements means before or at the point of accepting the instruction.
5. Ongoing CDD and Enhanced Due Diligence
Ongoing monitoring of client relationships is required from day one. For higher-risk clients — Politically Exposed Persons, clients from higher-risk jurisdictions, complex ownership structures — Enhanced Customer Due Diligence applies: additional source of wealth and funds information, senior management approval, more intensive monitoring.
6. Sanctions and PEP Screening
Every client onboarded for a designated service must be screened against Australian and international sanctions lists and global PEP databases before service commences.
7. Suspicious Matter Reporting
Red flags in the accounting context include clients reluctant to explain source of funds; requests to establish complex structures with no apparent commercial rationale; unexplained wealth inconsistent with declared business activities; and unusual urgency around transaction timing. Suspicious matter reporting is mandatory regardless of whether the transaction proceeds.
8. Staff Training and Seven-Year Records
Key obligations include training staff to implement the program, including identifying AML/CTF risks. All records must be retained for seven years.
9. Independent Program Evaluation
Your AML/CTF program must be independently evaluated at minimum every three years. For newly regulated practices, the first evaluation deadline runs from June 2029 to December 2030 based on your AUSTRAC account number.
The Three Practice Profiles
High-exposure practices routinely provide trust establishment, company formation, business acquisitions, financing facilitation, registered office services, and nominee directorships. Full Tranche 2 compliance infrastructure is required from day one.
Moderate-exposure practices provide some Table 6 services but not across their full client base. The obligation still applies wherever those services are provided.
Lower-exposure practices are genuinely limited to tax compliance, financial statement preparation, and general business advice. Tranche 2 exposure may be limited or absent — but the analysis must still be done and documented.
How Proximo Comply Solves This
Service Scope Analysis
Proximo Comply guides practice principals through a structured service inventory — every service mapped against the Table 6 categories, with AUSTRAC's advising vs. doing test applied at each step. The output is a documented service scope analysis that forms the foundation of your AML/CTF program.
AML/CTF Program Builder
With your service scope defined, Proximo Comply builds your program in the new outcomes-focused, risk-based format. Tailored to your practice's actual risk exposure, not a generic template. Version control, approval tracking, and review scheduling built in.
Digital KYC and Beneficial Ownership Workflows
Initial CDD for new clients is embedded in your service delivery process. For complex trust and corporate structures, the platform navigates the beneficial ownership chain to ensure every relevant party is identified and verified.
ECDD Triggers, Screening, and SMR Support
PEP status, high-risk jurisdiction connections, complex beneficial ownership, and wealth inconsistency indicators automatically trigger ECDD workflows. Real-time sanctions and PEP screening on every client. SMR red flags surfaced and lodgement supported.
Key Dates
| Date | What Happens |
|---|---|
| 31 March 2026 | AUSTRAC enrolment opens for Tranche 2 entities |
| 1 July 2026 | Full AML/CTF obligations commence. Program, KYC, governance, screening and reporting must all be operational. |
| 29 July 2026 | Final enrolment deadline. Final deadline to notify AUSTRAC of AML/CTF compliance officer. |
| June 2029 – Dec 2030 | First independent program evaluation due (date determined by AUSTRAC account number) |
Frequently Asked Questions
I'm a sole practitioner doing tax returns and financial statements. Do I need to comply?
If your practice is genuinely limited to preparing tax returns, financial statements, and providing general business advice — with no trust establishment, company formation, client money management, or registered office services — your Tranche 2 exposure may be limited. However, you should still complete a service scope analysis and document your conclusion.
My practice sets up family trusts and SMSFs. Is that caught?
Yes. Drafting a trust deed and facilitating the creation of a discretionary family trust or SMSF trust is a designated service under item 6 of Table 6. Your obligation commences the moment you accept and act on the client's instruction.
We act as registered office for client companies. Is that now regulated?
Yes. Providing a registered office address for an entity is a designated service under item 9, even as a minor, incidental, nominal-fee service. It triggers your enrolment obligation and requires KYC on the relevant entity before the service commences.