AUSTRAC just gave accountants what they’ve been waiting for. Last week they released the Accounting Program Starter Kit – step-by-step guidance, templates, and real examples.
If you’ve been putting this off because “the guidance wasn’t out yet” – that excuse is gone.
What the AML for Accountants Guidance Actually Includes
AUSTRAC put out a proper starter kit for accountants. Step-by-step stuff. Templates. Examples of how to deal with clients in real scenarios.
It’s designed for small, low-complexity firms. Which is most of us.
The guidance covers:
- How to build your AML/CTF program
- A document library with templates
- Real examples of client situations
- When you’re caught, when you’re not
If you haven’t looked at it yet: austrac.gov.au/reforms/sector-specific-guidance/accountant-guidance/accounting-program-starter-kit
The Timeline (Still the Same)
Nothing’s changed here:
- Now to March – Get your program sorted, train your team
- 31 March – AUSTRAC enrolment opens
- 1 July – Obligations kick in
Five months. It’s tight but it’s doable if you actually start.
What AUSTRAC Expects from Accountants
A lot of this stuff isn’t new work. It’s formalising what decent firms already do.
You probably already:
- Collect client details at onboarding
- Verify ID for ATO and TPB requirements
- Store documents
- Have engagement letters signed
- Know your clients reasonably well
The AML piece is about documenting it properly, adding a few extra checks, and having a system to track it.
What Seamlss Already Covers
We’ve been doing client onboarding for accounting firms for years. When I looked at what AUSTRAC actually requires versus what Seamlss already handles, a fair chunk is already there.
Already in Seamlss today:
| AUSTRAC Requirement | Seamlss Feature |
|---|---|
| Collect client identity info (name, DOB, address) | ✅ Client onboarding forms |
| Verify identity documents | ✅ ID verification (Stripe Identity, source docs) |
| Store records for 7 years | ✅ Document storage with retention |
| Digital signatures on agreements | ✅ E-signatures on engagement letters |
| Entity details (companies, trusts) | ✅ Entity management |
| Audit trail of who did what | ✅ History and activity logging |
| Client portal for updates | ✅ Client area |
What’s coming:
- AML screening (sanctions, PEP, adverse media)
- Risk assessment questionnaires matching AUSTRAC’s framework
- Beneficial ownership collection and tracking
- CDD workflows tied to your onboarding
- Review scheduling and reminders
- Compliance documentation and evidence storage
The point is: if you’re already using Seamlss for onboarding, you’re not starting from zero. You’ve got the foundation. We’re working on adding the AML layer on top – more details soon.
AML for Accountants: What to Do This Week
1. Read the starter kit
Not skim. Actually read it, here.
2. Figure out if you’re caught
Use AUSTRAC’s tool: Check if you may be regulated
If you’re setting up companies or trusts, acting as director or secretary for clients, providing a registered office address, managing ASIC lodgements, or handling money beyond your fees – you’re in. If you’re not sure, review the designated services list in the starter kit.
3. Pick someone to own this
Every firm needs an AML/CTF Compliance Officer. In most small practices, that’s you. The role can sit alongside other responsibilities, but someone has to own it.
4. Look at your client base
Who’s higher risk? International connections, cash businesses, complex structures? You don’t need software for this – a spreadsheet works fine to start.
Join Us Next Week
We’re running the next AML Accountants Forum on Wednesday 11 February at 12pm AEDT. This one’s focused on “Where do I actually start?” – walking through the starter kit and giving you a practical roadmap.
Free, online, no sales pitch. Agnieszka from LYRA and I break down what to focus on now versus what can wait.
Can’t make it live? Register anyway – we send the recording.
The Bottom Line for AUSTRAC Accountants
The guidance is out. The deadline is real. But this isn’t the disaster some vendors want you to believe.
If you’re a small to medium firm doing standard accounting work for mostly Australian clients, the requirements are manageable. AUSTRAC expects accountants to document their processes properly. If you’re already using Seamlss you’re almost there. Build a proportionate program. Document what you do and if you need too use AUSTRAC’s templates as your starting point
And if you’re already using Seamlss? You’re further ahead than you think.