Which accounting services are caught
Table 6 in s 6(5B) of the Act is profession neutral. Anyone who provides one of its services in the course of carrying on a business is a reporting entity. The examples below draw on AUSTRAC's guidance on professional designated services.
| Table 6 item | The service | How it shows up in an accounting practice |
|---|---|---|
| Item 6 | Assisting in the creation or restructuring of a body corporate or legal arrangement | Lodging the forms to register a company with ASIC, drafting or reviewing a trust deed or company constitution, mergers and demergers |
| Item 9 | Providing a registered office address or principal place of business address | Letting a client company use the practice's address as its registered office in place of the address it operates from |
| Items 7 and 8 | Acting as, or arranging for another person to act as, a director or secretary of a company, a trustee of an express trust, a partner, a power of attorney of a body corporate or legal arrangement, or a nominee shareholder | Nominee director or trustee roles, or arranging someone to fill them |
| Item 2 | Assisting in a transaction to sell, buy or transfer a body corporate or legal arrangement | Acting for a client in the sale of their company: negotiating, due diligence, valuation for the sale |
| Item 4 | Assisting in a transaction for equity or debt financing relating to a body corporate or legal arrangement | Structuring and negotiating a capital raising or loan for a client company |
| Item 3 | Receiving, holding and controlling (including disbursing) or managing a person's money, accounts or other property as part of a transaction | Receiving client money into the practice's bank account and paying third parties on the client's instructions |
Advice that only influences a decision is not enough
AUSTRAC guidance says a service is regulated under table 6 only when it directly advances the transaction or the creation or restructure of the entity. Its examples include:
- Tax advice on selling a company. A firm that advises on the tax implications of selling a body corporate is not yet providing a designated service. If it is then instructed to act for the client in the sale, the designated service begins from that point.
- Restructure of the legal form only. For item 6, restructuring means changing the legal form of the entity, including by merger or demerger. AUSTRAC says it does not extend to matters unrelated to legal form, such as staffing or IT systems.
- Setting up a trust. Explaining the steps and referring the client to a solicitor is not item 6. Taking steps to directly create the trust is, including acting on instructions to draft the deed, or giving advice comprehensive enough for the client to create the trust without further professional help.
Bookkeepers and client money
AUSTRAC guidance splits item 3 in two. Receiving, holding and controlling means the money comes to you and you control where it goes. Managing means you have authority and discretion to decide how a client's money is dealt with, even if you never hold it.
- Routine payments from the client's own account. AUSTRAC's example is a bookkeeper who processes payroll, supplier invoices, rent and tax remittances on fixed client instructions, with no discretion to redirect funds. AUSTRAC says that practice is less likely to be managing the client's money.
- Incidental payments. Item 3 does not apply if the practice provides no other designated service and the money is for payments reasonably incidental to a non-designated service (s 6(5C)(b)). This is assessed across the whole business. A bookkeeper who also provides a registered office address cannot rely on it.
- Paying a client's bills through your own account. AUSTRAC's example is a practice that receives client funds into its bank account and pays the client's lease and school fees. AUSTRAC says that is likely to be an item 3 service unless a s 6(5C) exemption applies.
- Your own fees and tax payments. Payment for your services is outside item 3 (s 6(5C)(a)). So are payments to or from a government body (s 6(5D)), and AUSTRAC lists tax payments to the Australian Taxation Office as an example.
The obligations in brief
- Enrol with AUSTRAC no later than 28 days after the day you start providing a designated service (s 51B). For a practice already providing one on 1 July 2026, the 28 days ran from that day.
- Have an AML/CTF program before you provide a designated service: a risk assessment (s 26C), policies (s 26F) and a compliance officer at management level (s 26J).
- Customer due diligence: initial, before you start the service (s 28); ongoing, while the relationship lasts (s 30); and enhanced for high-risk clients and foreign politically exposed persons (s 32).
- Report suspicious matters (s 41) and transfers of physical currency of $10,000 or more (s 43, within 10 business days).
- Keep records under Part 10 of the Act.
- Do not tip off (s 123).
AUSTRAC publishes an accounting program starter kit for practices with 15 or fewer personnel that meet its suitability criteria. AUSTRAC says you must assess whether it suits your practice.
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What to document for each client
Section 111 requires records reasonably necessary to demonstrate compliance with your customer due diligence obligations, including the type and content of the data collected and any analysis, risk assessment or decision making about the client (s 111(3)). For a client receiving a table 6 service:
- The service and the date it started. Which table 6 item, and when you began acting on instructions. For item 9, AUSTRAC guidance says the service starts when you make the address available to the client.
- The client's identity and how you established it (s 28(2)(a), s 28(3)(a)). AUSTRAC guidance says to record the details of the document used. The Act does not require a copy.
- Who the customer is for that item. For creating a company, table 6 names the person instructing you and the beneficial owners and directors of the company. For creating an express trust, it names the trustee, settlor and beneficiaries.
- Anyone the client is acting for, and anyone acting for the client with their authority (s 28(2)(b) and (c)).
- Beneficial owners of any non-individual client (s 28(2)(d)).
- Politically exposed person and sanctions status (s 28(2)(e)).
- The nature and purpose of the relationship or one-off transaction (s 28(2)(f)): why the client wants the company, the trust, the nominee or the address.
- The risk rating and the reasons (s 28(3)(b), s 111(3)(b)).
- Source of funds and source of wealth where your policies call for it. AUSTRAC's worked examples apply this check to higher-risk clients.
- What changed. New directors or shareholders, a change in what the entity is used for, unusual requests, and what you did (s 30).
- When the relationship ended. The 7-year period in s 111(2) runs from that date. A registered office service continues for as long as the client uses the address.
AUSTRAC's risk insights for accountants list behaviour to note when you see it: a client who is reluctant to prove their identity, who appears to be following a third party's instructions, who has changed advisers often without real reasons, or who is prepared to pay higher fees without a clear reason. AUSTRAC says one indicator on its own may not suggest suspicious activity.
What to record, when, and how long to keep it
| What to record | When | How long to keep it |
|---|---|---|
| Customer due diligence records: information collected, verification steps, risk rating and reasons, ongoing reviews | Before you start the designated service, then as things change | 7 years from when the business relationship ends or the one-off transaction is complete (s 111(2)) |
| Records sufficient to reconstruct each transaction relating to the service | As the transaction happens | 7 years from the day the record is made (s 107(3)) |
| Documents the client gives you about the service, or copies | When you receive them | 7 years after the document is given (s 108(2)) |
| AML/CTF program records: risk assessment, policies, approvals, training, reviews | As you build and run the program | Until 7 years after the record is no longer relevant to your Part 1A obligations (s 116(3)) |
| Suspicious matter decision records and copies of reports | When a concern is escalated and decided | Kept as program records, stored securely with restricted access |
| Records of tax agent services: nature, scope and outcome, advice received from and given to the client | As the service is provided | At least 5 years after the service has been provided (Tax Agent Services (Code of Professional Conduct) Determination 2024, s 30) |
How the Tax Practitioners Board rule sits beside it
Registered tax agents and BAS agents have a separate record duty. Section 30 of the Tax Agent Services (Code of Professional Conduct) Determination 2024, a ministerial determination that the Tax Practitioners Board administers, requires records that correctly record the tax agent services provided to each client. They must show the nature, scope and outcome of the service, include all advice received from and provided to the client, and be retained for at least 5 years after the service has been provided.
The two run from different dates. The Code's 5 years runs from when the service was provided. The AML/CTF Act's 7 years runs from the end of the relationship. Neither instrument says how they interact. On our reading each applies on its own terms, so a note that serves both is kept until the later of the two dates. Our guide to how long to keep file notes in Australia covers other professions.
Example file note: onboarding call
Fictional client and facts. The practice will register a company for the client (item 6) and provide its registered office address (item 9).
- What the client wants
Marcus is an electrician who has traded as a sole trader for six years. He wants to move the business into a company from 1 October 2026 and has asked us to register it. He also asked to use our office as the company's registered office, because he works from a van and a home garage.
- Who is involved
Marcus will be the sole director and sole shareholder. He confirmed no one else will own or control the company and he is not setting it up for anyone else. No one else is giving us instructions.
- Purpose
He has taken on two apprentices and a commercial fit-out contract, and wants limited liability and a simpler structure for employing staff. The company will carry on the same electrical contracting work for the same customers.
- Money
The company will be funded from the existing business account, with a starting balance of about $45,000 from trading income. No outside investors and no loans from third parties. We will not be holding or paying any money for him.
- Checks
- Explained that for company set-up and registered office services we must confirm his identity and ask standard questions under anti-money laundering law before we start.
- Asked whether he or a close family member holds a prominent public position in Australia or overseas. He said no.
- Onboarding form sent after the call. Identity verification, Australian Business Number search and screening to be completed on the due diligence form.
- What we told the client
We will not lodge the company registration or make our address available until the checks are complete. Engagement letter to follow.
- Next steps
- Marcus: return the onboarding form and identity document by 21 August 2026.
- Us: complete the due diligence form and risk rating, then confirm in writing that we can start.
- Ongoing: because the registered office service continues, review his details if the ownership or the nature of the business changes.
If a new shareholder appears a year later, this note is the baseline for the questions you ask under s 30.
Suspicions, reports and tipping off
A suspicious matter report is due within 3 business days after the day you form a suspicion on reasonable grounds, or within 24 hours if it relates to terrorism financing (s 41(2)). The grounds in s 41(1)(f) include information that may be relevant to the investigation of an evasion of a taxation law.
Section 123 makes it an offence to disclose that a report has been given or is required, or the report itself, where the disclosure would or could reasonably be expected to prejudice an investigation. The maximum penalty is imprisonment for 2 years or 120 penalty units, or both. AUSTRAC guidance says it expects suspicious matter records to be stored securely with access limited to authorised staff, so keep them separate from the client file the whole team works from.
Section 123(4) has an exception for a qualified accountant, defined in s 5 as a member of CPA Australia, Chartered Accountants Australia and New Zealand or the Institute of Public Accountants, who discloses information about a client's affairs in good faith to dissuade the client from conduct that could be an offence. AUSTRAC guidance says that even then you should not disclose that a report exists or is required. Section 242 preserves legal professional privilege, and AUSTRAC recommends that a reporting entity that is not a lawyer seek legal advice before withholding information on that ground.
Clients you already had on 1 July 2026
Section 36 treats a client as a pre-commencement customer if, at the start of 1 July 2026, the business relationship involved only table 5 services, table 6 services or item 2 of table 2. AUSTRAC guidance says this covers a customer you were providing a designated service to on 1 July 2026. On our reading that includes a client already using your address as its registered office on that date, though AUSTRAC does not give that example. Initial customer due diligence under s 28(1) does not apply to that client unless a suspicious matter reporting obligation arises, or there is a significant change in the nature and purpose of the relationship that results in medium or high risk (s 36(3) and (4)). You must still monitor for unusual transactions and behaviour (s 30(2)(a)) and for those changes (s 30(2)(d)).
Where a file note tool fits
To be plain about scope: CallNote is not an AML/CTF program, an identity verification tool or a reporting system. It does not verify documents, screen names or lodge reports with AUSTRAC. It helps you keep a consistent record of client conversations, which is where a client usually explains why they want a structure and who is behind it.
CallNote turns a call or meeting transcript that already exists into a structured file note. Transcripts arrive automatically from Aircall, Dialpad and Microsoft Teams, or you paste or upload one, or dictate a voice memo after a meeting. There is no accountant-specific template. You work from the general template or build one from a past note of your own. After review the note is sealed with a checksum and locked, and later changes are append-only amendments. We never record calls or join meetings, and data is hosted in Sydney.
On using AI with client information, see the Tax Practitioners Board's AI guidance for accountants and AI meeting notes for accountants.
Related guides: Tranche 2 for law firms, which covers privilege in more detail, and Tranche 2 for conveyancers, which covers real estate transactions.
Common questions
Does Tranche 2 apply to all accountants?
No. It applies to a practice that provides a designated service listed in table 6 of section 6 of the AML/CTF Act 2006, such as creating or restructuring a company or trust, helping buy or sell an entity, equity or debt financing for an entity, nominee and trustee roles, providing a registered office address, or handling client money in a transaction. Preparing tax returns and BAS is not listed in table 6.
Are bookkeepers caught by the AML/CTF reforms?
Only if they provide a table 6 service. AUSTRAC guidance says a bookkeeper who processes routine payments from a client's account on fixed instructions, without discretion to redirect funds, is less likely to be managing the client's money under item 3. Providing a registered office address (item 9) or arranging someone to act as a director (item 7) is a designated service.
Is providing a registered office address a designated service?
Yes, under item 9 of table 6. AUSTRAC guidance says it applies where you provide an address for a company or legal arrangement to use as its registered office or principal place of business in place of the address it operates from. The service starts when you make the address available, and the company is the customer.
When did accountants have to enrol with AUSTRAC?
The obligations started on 1 July 2026. Under s 51B of the Act, a practice must apply to enrol no later than 28 days after the day it starts providing a designated service. For a practice already providing one on 1 July 2026, the 28 days ran from that day. A practice that starts later has 28 days from the day it starts. AUSTRAC opened enrolment on 31 March 2026.
How long must accountants keep AML/CTF records?
Customer due diligence records are kept for 7 years from when the business relationship ends or the one-off transaction is complete (s 111(2)). Transaction records are kept for 7 years from the day the record is made (s 107). Client-provided documents are kept for 7 years after they are given (s 108). Program records are kept until 7 years after they stop being relevant (s 116).
Is the Tax Practitioners Board record rule the same as the AML/CTF rule?
No. Section 30 of the Tax Agent Services (Code of Professional Conduct) Determination 2024 requires registered tax and BAS agents to keep records of the tax agent services they provide for at least 5 years after the service has been provided. The AML/CTF Act requires customer due diligence records for designated services to be kept for 7 years after the relationship ends.