Accountants
Accounting firms providing certain services will be required to implement AML/CTF programs from 2026.
AML/CTF Amendment Act 2024 — Designated Non-Financial Businesses
AML/CTF Obligations
Enrol with AUSTRAC and implement a full AML/CTF program for designated accounting services
Conduct client due diligence on all clients receiving designated services
Identify the beneficial ownership of corporate and trust clients
Lodge SMR reports within 3 business days of forming a suspicion
Maintain all CDD and transaction records for 7 years
Conduct ongoing periodic review of client risk ratings and CDD documentation
Accounting firms must lodge SMR reports within 3 business days of forming a suspicion in connection with a designated service. Client confidentiality does not override your SMR obligation — the AML/CTF Act carve-out takes precedence.
Typical Customer Risk Profiles
Clients with offshore company structures — clients who own or operate businesses through offshore vehicles, particularly in low-tax or high-secrecy jurisdictions, warrant careful beneficial ownership analysis.
Clients with unusually complex structures for their apparent business activity — a small business with multiple holding companies, trusts, and offshore entities is a mismatch that requires explanation.
Clients seeking nominee arrangements — a request for you or your staff to act as a nominee director or shareholder is a significant ML risk flag that requires careful EDD.
Clients whose financial activity is inconsistent with their stated business — a client whose declared income is inconsistent with asset purchases or fund flows through their accounts should be reviewed.
Recommended Compliance Pack
Accountant Pack
Pre-configured for Accountants — KYC rules, risk thresholds, AUSTRAC report templates, CDD workflows, and monitoring rules aligned to your obligations. Ready from day one.
View pack detailsWhat's included
System default — customisableClient onboarding with identity verification and risk-based CDD for accounting designated services
Beneficial ownership mapping for complex corporate structures and multi-layered trusts
Ongoing periodic review scheduler to keep client CDD current and risk ratings reviewed
SMR case management and preparation tools for MLRO review before AUSTRAC lodgement
AML/CTF program template for accounting firms with designated service identification and training log
Example workflow
Default — you can modify stepsClient engagement letter signed
Engagement involves a designated service? CDD workflow triggered. Client intake form sent immediately.
Individual clients identified
Photo ID verification for individuals. Biometric check for high-risk or high-value clients.
Corporate structure mapped
Company or trust client? VeriGo maps ownership to identify all directors, shareholders, and UBOs.
UBOs verified and screened
All beneficial owners put through KYC, sanctions, and PEP screening.
Ongoing monitoring
Annual review reminders sent. Changes in ownership or risk profile flagged automatically.
Suspicion identified — SMR prepared
Unusual client instruction or financial pattern identified. MLRO reviews. SMR filed if required.
Pricing Recommendation
Recommended
Professional
Accounting firms with corporate and trust clients need full beneficial ownership mapping, periodic review scheduling, and MLRO case management. Professional covers all of this plus ongoing monitoring capabilities.
View full pricingReady to get compliant as a Accounting?
Your Accountant Pack is configured on day one. 7-day free trial — no credit card, no consultants, no configuration sprints.