AML/CTF Reforms from 1 July 2026: What Accountants and Regulated Businesses Need to Do Now

April 22, 2026

Introduction

If you’re running an accounting practice in Australia, this is a change you need to prepare for. There’s a change rolling in that a lot of people genuinely haven’t got their head around yet.

Starting 1 July 2026, roughly 90,000 businesses that have never thought twice about AUSTRAC are suddenly going to be sitting right in the middle of the country’s anti-money laundering regime. We’re talking about accountants. Lawyers. Real estate agents. Even the jeweller on the corner.

The real concern is that many businesses still have not taken meaningful steps to get ready.

This is one of the biggest compliance changes Australian professional services has seen in years. AUSTRAC has said the number of regulated businesses will rise from around 17,000 to more than 100,000 as tranche 2 entities come into scope.

So if you’re thinking “nah, this one’s not for me” — honestly mate, it probably is.

At Hughes O’Dea Corredig (HOC), we’ve been having the same conversation over and over for months. “Hang on, I have to register with AUSTRAC? Really?” So let’s keep this simple and actually walk through what’s coming, who’s in the gun, and what the savvy firms are already doing to stay a step ahead.

The Quick Version

Strip back the jargon and AML CTF reforms Australia is genuinely pretty simple at its core. From 1 July 2026, a huge slab of professions that were never touched by AML rules before are being dragged in. That’s basically it.

The bits worth knowing:

Start date: 1 July 2026 for tranche 2. You can get enrolled with AUSTRAC from 31 March 2026.
Who gets pulled in: Accountants, lawyers, real estate agents, conveyancers, and dealers in precious metals and stones. Offer a “designated service” and you’re in.
What you’ll need lined up: A written AML/CTF program, someone appointed as compliance officer, a proper way to work out who your clients actually are, a system for flagging anything that doesn’t smell right, and record-keeping that’s genuinely up to scratch.
Enrolment deadline: 29 July 2026, if you were already providing designated services on 1 July.
The regulator: AUSTRAC. They’re the federal financial intelligence watchdog.

Here’s the thing to grasp. This isn’t optional. If you provide these designated services from 1 July 2026, you must comply with the Act and Rules from that date, including enrolment and AML/CTF obligations.

Why This is Keeping Accountants Awake at Night

Look, we get it. You didn’t go into accounting to become a compliance officer.

You got into it because you’re sharp with numbers, good with clients, maybe you enjoy the puzzle of a complex tax situation. Now somebody’s asking you to run what’s basically a mini intelligence unit out of your practice.

Fair to say the mood out there is sitting somewhere between “mildly stressed” and “a bit panicked”.

The questions landing in our inbox tell the story pretty well.

“Am I even caught by this?” Easily the most-Googled question from practice owners right now. Short answer — if you help clients set up companies, operate trust accounts, deal with real estate transactions, act as trustee or director, or move money around on their behalf, you almost certainly are.

“I’m a sole practitioner. How am I supposed to run a whole compliance program?” A pretty legitimate worry for the thousands of smaller practices around the country. Silver lining though — AUSTRAC has put together Starter Kits specifically for small practices with 15 staff or fewer.

“How do I figure out beneficial owners for all my existing clients?” Honestly, a genuinely hard one. Especially if you’ve been working with some of them for twenty years on nothing more than a handshake and good faith.

“What happens if I just miss the deadline?” You can’t legally provide those designated services anymore. And the penalties are serious. AUSTRAC has been pretty upfront that they’re going to enforce.

The good news though? You’ve still got a runway. And you don’t need to figure all of this out on your own. A solid chat with a firm that’s already helping clients navigate AML CTF compliance Australia can take a surprising amount of weight off your shoulders in one sitting.

So What Are the AML/CTF Reforms, Actually?

The AML CTF reforms Australia sit under the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024. Most people call it the “tranche 2” reform because, well, it’s the second big wave of professions getting swept into the AML net.

Tranche 1 happened way back in 2006. That one caught the obvious crowd — banks, credit unions, remittance providers, casinos, crypto exchanges. Tranche 2 is now grabbing the professional services world.

Why, though? Because the international watchdog FATF has been leaning on Australia for years to close the gap. In regulator-speak, accountants, lawyers and real estate agents are what they call “gatekeeper professions” — sectors whose services could theoretically be used to move dirty money around if nobody’s checking.

So now, somebody’s checking.

The whole thing boils down to this. If your firm provides a designated service in Australia, you’ve got to register with AUSTRAC, run a proper compliance program, and flag anything that looks off.

That’s the 30-second version. The detail, as usual, is where it gets messy.

Who’s Actually Caught — And What Counts as a Designated Service

This is where a lot of accountants quietly convince themselves they’re exempt. And nine times out of ten, they’re wrong.

Under the reformed Act, you’re a newly regulated business AML CTF entity if you provide any of the following:

Helping clients buy or sell real estate. Supporting a client through a property deal? You’re in.

Holding or managing client money, securities, or other assets. This is the big one for accountants. If you run a trust account, you’re caught.

Setting up companies, trusts, or partnerships. Incorporating a Pty Ltd for a client? That’s a designated service right there.

Acting as — or arranging for someone else to act as — a director, trustee, partner, or nominee shareholder. Crazy common in accounting. Every single one of these is now regulated.

Providing a registered office or business address. Another bread-and-butter accounting service.

Helping with transactions involving digital assets or cryptocurrency. Less common in traditional practice, but worth flagging if it’s relevant.

AUSTRAC has the full list published, and honestly, it’s worth going through line by line with a highlighter.

Here’s the trap though. It’s not about whether you specialise in these services. It’s whether you provide them at all, even just occasionally. Help one client set up a trust this year? Congratulations, you’re regulated.

Why This Matters (Even for the Little Guys)

Here’s where a lot of smaller practices tune out. “Look, I’ve got 200 clients, none of them are running drug cartels. I’ll be fine.”

Totally understandable reaction. Also not quite how this works.

The law doesn’t grade on intent. It grades on whether you’ve got the systems in place. No program = non-compliant. Doesn’t matter if your clients are absolute saints.

AUSTRAC has made it crystal clear they expect effort. Their published regulatory expectations for 2025–26 don’t really leave room for “I didn’t know” as a defence after 1 July 2026.

The penalties are no joke. We’re talking civil penalties in the millions for serious breaches. And even for smaller issues, the reputational hit alone should be enough to worry about.

Your PI cover might not even touch it. Something plenty of firms haven’t properly thought through yet.

Banks are already paying closer attention. A few of the Aussie majors have started tightening scrutiny on trust accounts held by professional service providers. Expect this to only ramp up after July.

Bottom line, if you care at all about AUSTRAC compliance 2026, pretending this somehow won’t land in your lap just isn’t a strategy.

How the New Rules Actually Work

Now let’s look at how the new rules work in practice.

Step 1: Figure out if you provide any designated services

Print out the AUSTRAC designated services list. Grab a highlighter. Go through it line by line. Anything you do, even occasionally, that matches? You’re caught. Don’t guess on this one. Get it down on paper.

Step 2: Enrol with AUSTRAC

Enrolment opens 31 March 2026. If you’re already providing designated services on 1 July 2026, you’ve got until 29 July 2026 to get enrolment sorted. For anyone coming online after that, you’ve got 28 days from when you start providing the service.

Step 3: Appoint your AML/CTF Compliance Officer (AMLCO)

Every reporting entity has to have one. They’ve got to pass AUSTRAC’s “fit and proper person” test. For small firms this is usually just the principal. For bigger practices, often a senior partner or a dedicated compliance manager.

Step 4: Build your AML/CTF program

This is the real guts of the whole exercise. Your program has to cover:

A proper ML/TF risk assessment of your firm
Customer due diligence procedures — what you’ll check, when, how
Record-keeping systems
Internal escalation processes for suspicious matters
Staff training protocols
Governance and oversight structures
An independent evaluation process

Small firms with 15 staff or fewer can use AUSTRAC’s Starter Kit for accountants as a base and work from there.

Step 5: Start doing customer due diligence

Before you provide a designated service, you’ve got to identify and verify the customer. For some clients, that means genuinely digging into beneficial ownership. For higher-risk customers — like politically exposed persons — you’ll need enhanced customer due diligence on top of the basics.

Step 6: Set up your reporting channels

Certain matters have to be reported to AUSTRAC, including threshold transactions involving $10,000 or more in physical currency, international funds transfer instructions, and suspicious matters. Your systems need to be able to identify and escalate these appropriately.

Step 7: Keep records. Lots of them.

You’ve got to keep customer records, transaction records, and copies of every report you file. Typically for seven years.

An example that comes up a lot in our work. A firm helps a longstanding client set up a discretionary trust and takes on a directorship through a corporate structure. Under the new rules, that one job now triggers enrolment requirements, CDD on all beneficial owners, a risk assessment, file records, and potentially ongoing monitoring.

One engagement. Six compliance steps.

Want to see where you actually sit? A proper conversation with our team through business advisory is usually the quickest way to map it out.

Your Pre-1 July 2026 Checklist

Bookmark this bit. Here’s the checklist our team is actively running clients through right now.

1. Map every service you provide against the designated services list

Go through it line by line. Don’t guess, don’t assume. Services that feel harmless — acting as trustee, managing a trust account, setting up an SMSF — are all caught.

2. Pick someone to own it

Someone in the firm has to be accountable for this, otherwise it just won’t happen. Full stop.

3. Get moving on your risk assessment

Take a proper look at your client base, the services you offer, the geographies involved, and how you deliver (face-to-face versus remote). That’s the starting point for your ML/TF risk profile.

4. Rework your client intake process

Pretty much every accounting firm in Australia needs to upgrade onboarding. The whole “we’ve known this client for years, no need to bother with ID” era is officially done.

5. Don’t forget your existing client base

You’ll need to retrofit your due diligence across your existing book too. At least to a minimum standard. This takes time — start now, not in June.

6. Decide on your AMLCO

Whether that’s you, a partner, or someone external. Pick them, get them trained, document the appointment.

7. Decide — Starter Kit or custom build?

For smaller firms, the AUSTRAC Starter Kit is genuinely a great starting point. For bigger practices with more complex client work, you’ll probably need something more tailored.

8. Sort out your staff training

Everyone in the firm who touches client work needs training on red flags, reporting, and what to escalate. This needs to be done before 1 July. Not after.

9. Put a line in your 2026 budget for tech

You’ll likely need ID verification software, transaction monitoring, and record-keeping systems. Don’t let this catch you out mid-year.

10. Please don’t just download a template and pray

Genuinely the biggest mistake we’re seeing. Generic templates without proper tailoring will not survive an AUSTRAC review.

A proper sit-down with a firm that knows the landscape is honestly worth its weight in gold right now.

Common Myths Doing the Rounds

There’s a fair bit of rubbish floating around about these reforms. Let’s knock over the big ones.

Myth 1: “It’s only the big firms that get caught.”

Completely wrong. A sole practitioner who sets up one company structure in July 2026 is caught. Full stop. Size doesn’t matter here. Activities do.

Myth 2: “My professional body will sort this for me.”

Nope. CPA Australia, CA ANZ and IPA can give you guidance and training, but the actual compliance obligation sits with your firm and your AMLCO. They’re not going to do it for you.

Myth 3: “I’ll just outsource it all and forget about it.”

Parts of it you can absolutely outsource — technology, independent reviews, training. But the compliance obligation still sits with you. You can outsource the admin. You can’t outsource accountability.

Myth 4: “If I get a driver’s licence copy, I’m fine.”

Not really. The new regime expects a proper risk-based approach, including actually understanding what the client relationship is for and keeping an eye on things over time. A quick ID scan won’t cut it.

Myth 5: “I’ll just wait for AUSTRAC to come knocking.”

Terrible plan. AUSTRAC has made it very clear they expect you to be operational before 1 July 2026 — not scrambling afterwards.

Myth 6: “The Starter Kit is enough on its own.”

The Starter Kit is a brilliant starting point. But it’s a framework, not a finished compliance program. You still have to customise it to your actual firm, roll it out properly, train your people, and keep it up to date.

When to Start — Seriously, Now

There was a sweet spot for getting ahead of the AML CTF reforms 1 July 2026. It was about 12 months ago.

The next best time is today.

Get moving now if:

You’re an accountant, lawyer, real estate professional, or anyone offering designated services
You run client trust accounts or help structure companies and trusts
You act as director, trustee, or nominee for any clients
You provide registered offices or business addresses
You work with clients involved in property transactions

Treat it as urgent if:

You’ve got 50+ clients you’ve provided designated services to
You’ve got high-value or complex client structures on your books
You’ve got international clients or anyone connected to higher-risk jurisdictions
You’re heading into 1 July 2026 without an AMLCO picked yet
You haven’t even started on enrolment prep

Firms that get moving now will glide into 1 July 2026 without too much drama. The ones that leave it until May? They’ll be paying rush fees, fighting with AUSTRAC systems during peak load, and almost certainly missing pieces.

Don’t be that firm. Book a compliance review and get on the front foot.

How HOC Helps Accountants and Regulated Businesses Get Ready

This is where Hughes O’Dea Corredig comes in. We’re a Melbourne firm, based in Essendon, and we’ve been looking after accountants, business owners, and professional service firms across greater Melbourne for decades.

What we’re not is a one-trick accounting shop. What we are is a team that helps businesses navigate exactly this kind of regulatory minefield — practically, without the jargon, and in a way that actually leaves you with a plan.

Tax Planning and Compliance

For fellow accounting practices getting ready for tranche 2, our tax planning and compliance team can work alongside your existing setup to help map designated services, spot the gaps, and line up AML/CTF requirements with your broader tax compliance obligations. They overlap more than most firms realise.

SMSF Services and Structuring

If you run SMSFs — or help clients set them up — our SMSF team is across the crossover between SMSF compliance and the new AML/CTF rules. Every corporate trustee appointment, every fund setup, every restructure is now a designated service. It all needs handling properly.

Business Advisory and Governance

Through our business advisory practice, we help firms stand up the governance structures, risk frameworks, and internal processes that AUSTRAC will expect to see. This is where a lot of smaller practices really struggle. We can help lift that load.

Whether you’re up the road in Essendon or dialling in from anywhere in Australia, our team delivers the kind of practical, no-nonsense AUSTRAC compliance support for accountants that actually gets firms across the line.

FAQs — AML/CTF Reforms Answered

What are AML CTF reforms?

Basically, they’re updates to Australia’s Anti-Money Laundering and Counter-Terrorism Financing Act 2006 that push the number of regulated businesses from roughly 17,000 all the way up to over 100,000. The fresh group getting swept into the net includes accountants, lawyers, real estate agents, conveyancers, and anyone who deals in precious metals.

When do AML CTF reforms start in Australia?

Enrolment for newly regulated businesses opened on 31 March 2026. Newly regulated tranche 2 businesses need to comply with the new AML/CTF obligations from 1 July 2026, and businesses already providing designated services on that date generally need to enrol by 29 July 2026.

Do accountants need AML CTF compliance?

If you provide any designated service — and most accountants do — yes. Setting up companies, acting as trustee, running trust accounts, helping with real estate transactions — all designated services.

What is a newly regulated business?

Any business being brought into the AML/CTF regime for the first time under the 2024 reforms. Mostly the tranche 2 crowd — accountants, lawyers, real estate folks, jewellers — plus a handful of virtual asset service providers.

What is customer due diligence?

Put simply, it’s the job of figuring out who your customer actually is, getting your head around what the business relationship is actually for, and weighing up any money laundering or terrorism financing risk they might bring to the table. It’s basically the foundation of your whole compliance program.

Do I need to register with AUSTRAC?

If you provide designated services, yes. You can start enrolling from 31 March 2026. But if you’re already providing designated services on 1 July 2026, you’ve got to have it done and dusted by 29 July 2026.

What are the penalties for getting it wrong?

Not fun. Civil penalties can run into the millions for the bigger breaches. Even smaller matters carry significant fines. Plus there’s the reputational hit and the risk of losing the ability to legally provide those services.

Is the Starter Kit enough on its own?

No. The Starter Kit is a useful framework to build from, but you’ve still got to customise it to your firm, your clients, and your actual risk profile. It’s a template, not a free pass.

Why Our Advice Holds Up

Let’s be real. This is a genuinely complicated bit of legislation. Getting it wrong — or pulling something generic off a template site — can cost you six figures in penalties, and a lot more in lost client trust.

Here’s why firms across Melbourne keep coming back to Hughes O’Dea Corredig:

Decades of experience guiding Melbourne accounting practices, professional firms, and business owners through regulatory change
Registered Tax Agents and qualified professionals keeping a close eye on AUSTRAC, FATF, and Home Affairs developments
Integrated service — tax, SMSF, business advisory, estate planning, and financial planning all sitting under one roof
Genuine working knowledge of how AUSTRAC guidance, Attorney-General’s Department releases, and industry bodies like CPA Australia and CA ANZ are reading the new rules
A practical, no-jargon approach that actually ends up with useful advice for your firm

Reviewed by the HOC compliance and business advisory team, April 2026. This article is general information only and isn’t a substitute for tailored legal or compliance advice.

Your Next Step — Book a Compliance Review

If you run an accounting firm, law practice, or any kind of professional service business caught by AML CTF reforms Australia 2026, the smartest move you can make right now is sitting down with someone who’s already helping clients through it.

Book your compliance review

Our team offers a confidential compliance review session where we map your current services against the designated services list, walk through where the gaps are, and put together a clear plan for 1 July 2026.

Call HOC on +61 3 9375 4286 or email mail@hoc.com.au to lock in a time.

Or have a look around first

Not quite ready to book? Start with our tax planning page, SMSF services, or business advisory services to get a feel for how we work.

Related Resources

Wrapping Up

Let’s pull it together.

The AML CTF reforms Australia rolling in from 1 July 2026 aren’t just more regulatory noise to ignore. This is the biggest shift in Australian professional services compliance in a generation. We’re talking about 90,000 businesses suddenly finding themselves on the inside of a regulatory regime they’ve never had to touch before.

Is it a significant body of work? Yes. Do the starter kits and checklists help? Absolutely. But they still need to be tailored properly to your firm, your services, and your risk profile.

Here’s the thing though. The firms that engage now — who map their services, build their program, appoint their AMLCO, train their people before the deadline — they’ll be absolutely fine. They’ll keep providing services, keep their clients, keep earning.

The ones who leave it until May or June 2026? They’ll be paying for rush jobs, missing pieces, and scrambling while everyone else is already operational and sorted.

Don’t be in that second group.

Book your AML/CTF compliance review with Hughes O’Dea Corredig and walk into 1 July 2026 with a plan. Not a panic attack.

Hughes O’Dea Corredig is a Melbourne accounting firm specialising in tax planning, SMSF, business advisory, financial planning, succession, and estate planning. Based in Essendon, we look after clients across greater Melbourne and nationally via secure remote service. Information in this article is general and current as of April 2026. Please get personalised advice before making any compliance decisions.

Our Core Services:
Wealth Management • Tax Advisory • Superannuation • SMSF Management • Business Accounting • Business Adviosry , Retirement Planning etc.

🌐 www.hoc.com.au | 📍 Level 2, 333 Keilor Road, Essendon VIC 3040 | 📧 mail@hoc.com.au

Connect with Us

Follow our latest insights and expert opinions:
🔗 LinkedIn 📘 Facebook

Categorised in: Uncategorized