Updated September 2026. We first wrote this in December 2025, before AML/CTF obligations for accountants started on 1 July 2026. The questions firms ask have barely changed. Some of the answers have, because AUSTRAC has since published guidance that settles points we could only estimate then. Each answer now reflects that guidance as at September 2026 and links to the AUSTRAC page it comes from.
Every AML webinar ends the same way. The formal presentation finishes, the slides stop, and then the real questions start. That is when you find out what is actually worrying people.
For context: when we polled webinar attendees in late 2025, 58% said they had not started preparing. Another 35% had started researching but were not sure what to do. Only about 7% felt mostly sorted.
1. Do I need to verify all my existing clients?
No. Not all at once, and for many of them not until something changes.
AUSTRAC calls a client a pre-commencement customer if you were providing them a designated service on 1 July 2026, or you had a business relationship with them that involved a designated service provided before that date. You can keep providing designated services to a pre-commencement customer without initial customer due diligence (CDD) unless one of two things happens:
- a suspicious matter reporting obligation arises for that client, or
- there is a significant change in the nature and purpose of the business relationship, and it means the client’s money laundering or terrorism financing risk is medium or high.
If either happens, you complete initial CDD before you provide them with a designated service. Source: AUSTRAC, transitioning existing customers.
One correction to what we wrote in December. We said any new designated service for an existing client would need CDD. AUSTRAC’s guidance is narrower. Its example of the trigger is a client requesting a new service in a way that differs from your existing relationship, where that makes their risk medium or high. Continuing the kind of work you already do for them does not, on its own, trigger initial CDD.
What you do owe pre-commencement customers is ongoing CDD. AUSTRAC lists three parts: watch for unusual transactions or behaviour that could lead to a suspicious matter report, review and update their know your customer information at an appropriate frequency, and watch for the significant changes described in the second trigger.
2. We use our office as the registered address for clients. Does this trigger AML?
Yes. Providing a registered office address or principal place of business address for a company or other legal arrangement is a designated service, item 9 on AUSTRAC’s list. Source: AUSTRAC, professional designated services.
Lots of firms do not think of it as a service. It was set up years ago and nobody looks at it until ASIC sends a letter. Under the reforms, it counts.
Arrangements in place before 1 July 2026 fall under the pre-commencement rules in question 1, and the triggers for CDD are the same two: a suspicious matter reporting obligation, or a significant change in the relationship that takes the client’s risk to medium or high. An address change or an ASIC notice only matters if it amounts to one of those.
Whether to keep providing the service is a business decision. Some firms are stopping it, others are keeping it inside their AML program. What stopping removes, and what it does not, is in Should your firm still be the registered office?
3. I act as a director or shareholder for clients, for estate planning and similar. Am I caught?
Possibly. AUSTRAC’s guidance now says where the line sits, and it turns on whose instructions you follow.
Item 7 covers acting as, or arranging for someone to act as, a company director or secretary, a partner, a trustee of an express trust, or an equivalent position, on behalf of another person. Item 8 covers acting as a nominee shareholder on behalf of another person. AUSTRAC describes acting as a director on behalf of a customer as the customer keeping control, with the director acting on the customer’s wishes and instructions.
Two limits matter for accountants. Acting only as a filing agent, representative or service provider carrying out administrative or procedural steps does not, by that fact alone, fall within item 7. And item 7 does not apply to trustees or executors of testamentary trusts. Source: AUSTRAC, professional designated services.
So if you hold a directorship, trusteeship or shares in a client structure and act on what your client wants, read items 7 and 8 closely and record your reasoning either way. Arrangements in place before 1 July 2026 fall under the pre-commencement rules in question 1, but they still belong in your AML program.
4. What about existing clients with foreign shareholders who we make payments for?
Two separate questions here.
Making payments for clients: receiving, holding, controlling or managing a client’s money or property as part of a transaction is item 3. AUSTRAC draws a useful line. Managing means having authority and discretion over how the money is dealt with. Where your role is confined to carrying out fixed, binding instructions, such as routine payment administration, with no discretion to redirect funds, you are less likely to be managing. If client money comes into your own account and you hold it and control where it goes, you are likely receiving, holding and controlling it. Source: AUSTRAC, professional designated services.
Foreign shareholders: having foreign shareholders does not automatically make a client high risk, but it is a factor in your risk assessment. A majority foreign shareholder, particularly from certain jurisdictions, may raise the rating.
For existing clients the pre-commencement rules in question 1 apply. If you make payments for clients with complex ownership, ask whether your ongoing monitoring would pick up anything unusual, because ongoing CDD on pre-commencement customers is now an obligation.
5. If a client is high-risk, won’t they know they’re being assessed?
Yes. And that’s fine.
This worry comes up a lot. Accountants don’t want to offend clients or make them feel suspected of something.
But AML obligations now reach accountants, lawyers and real estate agents too, and financial advisers have worked under them for years. Your legitimate clients will understand you’re meeting regulatory requirements, not accusing them of anything.
Enhanced due diligence might mean asking about source of funds, understanding their business activities better, or getting senior approval within your firm before acting. These are reasonable questions in a professional relationship.
If a client reacts badly to basic compliance questions, that’s actually information worth having.
6. If a client receives cash and we know about it for tax, do we need to report it?
Not automatically.
A threshold transaction report applies when you receive or pay $10,000 or more in physical currency, and it is due within 10 business days of the transaction. Source: AUSTRAC, threshold transaction reports. If your client’s business receives cash and tells you about it for their BAS or tax return, that’s different from you handling the cash yourself.
But this is where ongoing monitoring matters. If you know a client routinely receives large amounts of cash, and it seems inconsistent with their business type or declared income, that’s worth examining. Cash-intensive businesses aren’t inherently suspicious. Unexplained cash is.
7. Why aren’t financial planners caught?
They largely already are, through different mechanisms.
Financial planners work through product providers: fund managers, platform operators, insurance companies: who are already reporting entities under the existing AML regime. When they complete forms for investment bodies, those bodies are doing the AML checks.
The reforms that started on 1 July 2026 brought in professional services that were not previously covered: accountants, lawyers, real estate agents, and trust and company service providers.
If a financial planner is also providing accounting services or setting up structures, they’d be caught for those activities like any other accountant.
What to do now
AUSTRAC set out what it expects of newly regulated firms by 1 July 2026:
- be enrolled with AUSTRAC as a reporting entity
- have an AML/CTF program, either AUSTRAC’s starter program or your own
- have an AML/CTF compliance officer
- have trained your staff on the program
- be ready to ask clients questions and report suspicious activity.
If you have not enrolled, fix that first. A firm must apply to enrol no later than 28 days after it starts providing a designated service (AUSTRAC, enrol with us). AUSTRAC has said its enforcement in the newly regulated sectors will focus on firms that wilfully ignore the obligation to enrol, and on those it suspects are complicit with, or wilfully blind to, money laundering. It has also said it does not expect newly regulated businesses to be perfect from day one; it expects honest efforts.
AUSTRAC publishes an accountant program starter kit.
The three things we suggested in December still hold, in a different tense:
- Know which designated services you provide. Many firms find they provide more than they thought: registered office services, nominee arrangements, client money.
- Treat existing clients as pre-commencement customers: keep up ongoing CDD, and complete initial CDD when a trigger in question 1 occurs.
- Make new client onboarding the place CDD happens, so identity, screening and the risk rating are complete before you start work.
How Seamlss helps
Seamlss runs the AML checks inside client onboarding: identity verification, PEP and sanctions screening, and beneficial ownership, with adverse media screening inside the risk assessment tool. The AML Compliance Hub shows your firm’s AML position in one place. The risk assessment tool lets you build your firm’s risk profile, or adapt the AUSTRAC standard profile as a starting point, then assess each client against it. Your firm still makes the determination; Seamlss records it. AML tools are available on paid plans, and the in-app help covers how each one works.
More in this series
- Tranche 2 for Accountants: What Onboarding Actually Looks Like
- What an AML Check Actually Looks Like for an Accounting Firm
To see how Seamlss handles these checks inside onboarding, see plans and pricing.
AML checks, inside onboarding rather than bolted on
Identity verification, screening and record keeping happen as the client comes on board. Try the platform free for 14 days. AML tools are available on paid plans.
