Tranche 2 AML/CTF · Accounting Firms · 1 July 2026
AML/CTF compliance for accounting firms, ready before 1 July 2026.
If your accounting practice provides certain designated services, you must enrol with AUSTRAC and have an AML/CTF program in place from 1 July 2026. GateCrown helps you build yours. Customised to your practice, built from AUSTRAC's published guidance.
Enrolment opens
31 Mar 2026
AUSTRAC enrolment portal goes live
Obligations begin
1 Jul 2026
AML/CTF program must be in place
Enrolment deadline
29 Jul 2026
Last day to enrol with AUSTRAC
Who is regulated
Does this apply to your practice?
From 1 July 2026, accounting practices providing "designated services" must have their AML/CTF program, compliance officer, and staff training in place. They must also be enrolled with AUSTRAC by 29 July 2026. Size does not exempt you.
The trigger is where an accountant assists in planning or execution of, or acts for or on behalf of a client in a sufficiently direct way (Table 6, subsection 6(5B) of the AML/CTF Act). General advice alone is generally not captured.
If your practice provides any of the services listed, you may be a reporting entity. Many practices that only do tax, BAS, audit, or standard financial reporting will not be captured. Use AUSTRAC's online tool to confirm.
Non-compliance penalties
Individuals (partners, directors)
$6,600,000
Body corporate (the practice entity)
$33,000,000
Per contravention under the AML/CTF Act 2006 (Cth). Penalty unit values are subject to indexation.
Your practice is captured if you provide:
Company formation & management
Directly assisting or acting on behalf of a client to create, operate, or manage a body corporate, including executing steps in a company setup, acting as a registered agent, or carrying out company secretarial actions at a client's direction.
Trust creation & management
Directly assisting or acting on behalf of a client in creating, operating, or managing a trust or other legal arrangement, including drafting trust deeds, executing trust structures, or taking steps to bring a legal arrangement into existence.
Business buy/sell transactions
Directly assisting in planning or execution of, or acting for or on behalf of, a client in the buying, selling, or transferring of a business or an interest in a business.
Managing client money or assets
Managing funds, securities, accounts, or other assets on behalf of a client, including holding funds in a client trust account and executing transactions on their instructions.
Executing financial transactions
Acting on behalf of a client to buy, sell, or transfer financial instruments, real property, or other assets, where the accountant is facilitating or executing the transaction rather than merely advising.
Generally not captured on their own: Tax return preparation, BAS preparation, standard financial statements, audit, and general financial advice, where no action is taken on behalf of a client to execute a transaction or create a structure. However, if a service involves both advisory and execution elements, the execution component may be captured. Confirm your specific services using AUSTRAC's online tool.
Captured? We can have your documentation ready in 10 to 14 business days.
Book a Free Scoping Call → See PricingOur process
Target turnaround:
10–14 business days
We prepare your documentation pack after receiving your completed onboarding information. You review, approve, and implement.
01
Intake & scoping
30-minute call. We assess which designated services your practice provides and map your risk profile.
Day 1–202
Enrolment preparation
We prepare your AUSTRAC Business Profile Form and guide you through the enrolment process.
Day 3–403
Risk assessment
We build your documented, practice-specific ML/TF risk assessment covering clients, services, channels, and jurisdictions.
Day 4–704
AML/CTF program
We draft your AML/CTF program document, CDD policies, onboarding forms, and process documentation.
Day 7–1105
Training & handover
Staff training materials, compliance officer briefing, and handover of your complete documentation pack.
Day 12–14What you receive
Your compliance documentation pack
All documents delivered in editable Word and Excel formats. Yours to keep and update.
01 / Foundation
AUSTRAC Enrolment
Enrolment preparation and guidance, including Business Profile Form completion.
Business Profile Form preparation
Designated services identification
Key personnel details
Enrolment step-by-step guide
02 / Core document
ML/TF Risk Assessment
A documented, practice-specific risk assessment covering ML/TF and proliferation financing risks.
Service-by-service risk mapping
Client type risk ratings
Delivery channel risk analysis
Jurisdiction and geography risks
PEP and sanctions screening framework
03 / Core document
AML/CTF Program
The written program document tailored to your practice. This is a key document AUSTRAC may request during a compliance examination.
AML/CTF policies and procedures
Governance structure documentation
Compliance officer appointment
Senior manager approval process
Program review schedule
04 / Operational
Customer Due Diligence Framework
CDD policies and forms for onboarding and monitoring clients under the new regime.
Initial CDD policy and process
Ongoing CDD monitoring procedures
Enhanced CDD for high-risk clients
Individual client onboarding forms
Corporate/trust entity forms
Beneficial owner identification forms
05 / Operational
Reporting & Records Framework
Policies and registers for transaction reporting obligations and mandatory record-keeping.
Suspicious Matter Report (SMR) process
Threshold Transaction Report (TTR) policy
Record-keeping register and schedule
Annual compliance report template
7-year retention procedures
Independent evaluation framework
06 / People
Staff Training Module
Practical, role-appropriate AML/CTF training materials for all practice personnel.
Accountant-specific training content
Red flags and suspicious activity
CDD in practice: worked examples
Compliance officer role briefing
Training completion records
Pricing
Fixed-fee documentation.
No surprises.
One engagement, one price. Sized to your practice.
All prices in AUD. GateCrown is not currently registered for GST. No GST is charged. See Terms for details.
Solo & Micro
Sole practitioners and practices with 1–3 staff providing one or two designated services, primarily to individual Australian clients.
$4,500
AUD · Fixed fee
- AUSTRAC enrolment preparation
- ML/TF risk assessment (1 service type)
- AML/CTF program document
- CDD policy and 3 onboarding forms
- SMR and record-keeping procedures
- Staff training materials (up to 3 staff)
- Compliance officer appointment template
- Program review (add-on, see below)
Most common
Small Practice
Practices with 4–10 staff providing 2–3 designated service types, with a mix of individual and business clients.
$7,500
AUD · Fixed fee
- AUSTRAC enrolment preparation
- ML/TF risk assessment (all service types)
- AML/CTF program document
- Full CDD framework + 6 onboarding forms
- SMR, TTR, and record-keeping procedures
- Staff training materials (up to 10 staff)
- Compliance officer appointment + briefing
- 30-day post-delivery support window
- One round of revisions included
Medium Practice
Practices with 11–15 staff, complex client base including corporate/trust clients, or practices providing all designated service types.
$11,000
AUD · Fixed fee
- AUSTRAC enrolment preparation
- Comprehensive ML/TF risk assessment
- Full AML/CTF program + policy suite
- Complete CDD framework + enhanced CDD
- Full reporting and records framework
- Staff training materials (up to 15 staff)
- Compliance officer full briefing materials
- 60-day post-delivery support window
- Two rounds of revisions included
Add-on
AML/CTF Program Review & Independent Evaluation
Your risk assessment and AML/CTF policies must be reviewed at least every 3 years. Separately, your program must be independently evaluated by someone outside the program at least every 3 years; for newly regulated entities the first deadline is 1 July 2029.
$1,500/review
Annual or as-needed
Important: The AUSTRAC Accounting Profession Starter Kit is designed for practices with 15 or fewer personnel and a straightforward client base. If your practice has more than 15 staff, regularly deals with high-risk international clients, or has complex multi-jurisdictional operations, contact us for a custom engagement.
How we compare
Choosing the right approach
The comparison below represents GateCrown's own assessment. Turnaround times, costs, and service scope vary by provider. Regulatory facts are sourced from AUSTRAC; commercial comparisons are GateCrown's positioning.
| What you need | DIY (AUSTRAC Starter Kit) | Your accountant network | A law firm | GateCrown |
|---|---|---|---|---|
| AUSTRAC enrolment guidance | × You do it | ~ May help | ✓ | ✓ |
| Risk assessment tailored to accountants | ~ Template only | × Not their product | ✓ | ✓ |
| Fixed price, no hourly billing | ✓ Free (your time) | × Hourly, open-ended | × Typically hourly | ✓ Fixed fee |
| Target turnaround under 2 weeks | × Significant time investment | × Timeline varies | ~ Depends on firm | ✓ 10–14 days |
| Staff training materials included | × Build yourself | × Separate engagement | × Separate engagement | ✓ Included |
| CDD forms and onboarding templates | ~ Word templates | × | ~ Extra cost | ✓ All forms included |
| Built from AUSTRAC Accounting Starter Kit | ✓ Source material | × | ~ May use it | ✓ Foundation framework |
| Typical cost | Free template (plus your time) | Varies, often hourly | Varies by firm | $4,500–$11,000 |
Frequently asked
Common questions
We only do basic tax returns and BAS. Are we captured?
Generally no, if that is genuinely all you do. Tax return preparation, BAS preparation, financial statement preparation, and standard audit work are generally not captured on their own. You are only captured if you also provide services like company formation, trust creation, business transaction facilitation, or managing client funds. We recommend confirming via AUSTRAC's online tool.
Can I just use the free AUSTRAC Starter Kit myself?
Yes, and for very simple practices with one service type and low-risk clients, it can work. The practical challenge is time and risk. Properly customising the Starter Kit requires reading AUSTRAC's guidance in full, working through the risk assessment, drafting policies tailored to your practice, and training your staff. GateCrown is designed to reduce that friction.
What if my practice also does conveyancing?
AUSTRAC's guidance for mixed legal/conveyancing practices indicates that where a practice provides both legal and conveyancing designated services, it may need to maintain separate risk assessments for each service type. Inform us during intake so we can assess whether one or two risk assessments are needed.
Do we need to re-identify all existing clients from 1 July?
Not necessarily. You must complete initial CDD before providing a new designated service to a client from 1 July 2026. If you have an ongoing relationship and continue the same designated service, you apply ongoing CDD rather than starting from scratch.
Who needs to be the AML/CTF compliance officer?
The compliance officer manages day-to-day AML/CTF compliance. For typical accounting practices, this is usually the office manager or a senior partner. It does not need to be a compliance specialist, but it does need to be someone with appropriate authority and an understanding of their responsibilities.
What happens if AUSTRAC audits us?
AUSTRAC can conduct a compliance examination at any time. They will request your AML/CTF program document, risk assessment, CDD records, training records, and transaction reports. GateCrown's documentation is designed to support your compliance position, though the outcome of any examination depends on how you implement and maintain your program.
Is AUSTRAC likely to enforce against small practices?
AUSTRAC's published guidance indicates that businesses ignoring these changes will face consequences and that practices should not assume being small provides exemption. The enforcement pattern from comparable jurisdictions shows that early enforcement actions are often used to signal expectations.
We have more than 15 staff. Can you still help?
Yes. Practices with more than 15 staff, complex international client bases, or unusual risk profiles require a custom AML/CTF program beyond the AUSTRAC Starter Kit framework. Contact us for a scoping conversation and custom quote.
What compliance looks like
Your ongoing obligations
after 1 July 2026
By 1 July 2026
AML/CTF program, compliance officer & training
You must have your AML/CTF program, compliance officer, and staff training in place by 1 July 2026. Separately, you must be enrolled with AUSTRAC by 29 July 2026.
Before every client
Initial customer due diligence (CDD)
Before you start providing a designated service, you must complete initial CDD: verifying the client's identity and assessing their ML/TF risk level. This applies even to existing clients where a new designated service relationship is commencing.
Ongoing
Ongoing CDD and transaction monitoring
You must continuously monitor client relationships for changes in risk profile, unusual transactions, and red flags.
As required
Suspicious Matter Reports (SMR)
If you suspect ML/TF activity, you must report to AUSTRAC: within 24 hours for terrorism financing, or as soon as practicable and within 3 business days for other suspicious matters.
As required
Threshold Transaction Reports (TTR)
Where a designated service involves physical currency of AUD $10,000 or more, a TTR must be submitted within 10 business days.
Annual
Annual AML/CTF compliance report
Lodge annually with AUSTRAC covering the previous calendar year, submitted between 1 January and 31 March. First report covers 2026, due January to March 2027.
At least every 3 yrs
Review and update your AML/CTF program
Review your risk assessment and policies at least every 3 years, and whenever triggered by significant business changes. Updates must be documented within 14 days and approved by a senior manager.
At least every 3 yrs
Independent evaluation
Your AML/CTF program must be independently evaluated by someone not involved in developing or maintaining it. First deadline for newly regulated entities: 1 July 2029.
At least 7 years
Record-keeping
All AML/CTF records must be retained for at least 7 years. AUSTRAC can request these records at any time during a compliance examination.
Key dates for your practice
✓
December 2024
AML/CTF Act amendment passed
Parliament passed the AML/CTF Amendment Act, making Tranche 2 obligations law.
✓
29 January 2026
AUSTRAC Accounting Starter Kit released
AUSTRAC published the official Accounting Profession Starter Kit.
→
31 March 2026
Enrolment portal opens
AUSTRAC enrolment system goes live for Tranche 2 entities.
!
1 July 2026
Full obligations commence
Your AML/CTF program must be in place before you start providing designated services from this date.
!
29 July 2026
Enrolment deadline
All Tranche 2 entities must be enrolled with AUSTRAC by this date.
→
January to March 2027
First compliance report due
Your first annual compliance report covers the 2026 calendar year.
GateCrown recommendation
Book your engagement in March or April 2026 to allow time for intake, scoping, documentation, and AUSTRAC enrolment before obligations begin 1 July.
Get started
Book a scoping call
for your practice
Enrolment opens 31 March. Obligations begin 1 July. We help you build the documentation. You approve, implement, and maintain it.
Or email us at hello@gatecrown.com
1 We reply within 2 business hours
2 30-minute scoping call
3 Proposal same day
✓ Fixed-fee, no surprises
✓ Built from AUSTRAC's published guidance
✓ Target: 10–14 business day delivery
✓ You approve, implement, and maintain
Important: GateCrown is not a law firm, accounting firm, or licensed compliance advisor. Our documentation is based on publicly available AUSTRAC guidance and the AML/CTF Rules 2025. It does not constitute legal advice. You should seek independent legal advice before relying on any documents for AUSTRAC registration or compliance purposes. Compliance depends on how you implement and maintain the program.