1. Enrol with AUSTRAC
Within 28 days of first providing a designated service, through AUSTRAC Online. Free. Update it if your services or compliance officer change.
2. Adopt an AML/CTF program
A written document with a risk assessment of your firm and the policies you follow. Senior management must approve it. It must be kept current and reviewed, with an independent evaluation at intervals.
3. Appoint an AML/CTF compliance officer
A person at management level, usually the principal in a small firm. They own the program, training and reporting.
4. Customer due diligence before the service
Identify and verify each client, and the beneficial owners of any company or trust, using reliable and independent documents. Understand the purpose of the relationship. Apply more checks to higher-risk clients such as politically exposed persons.
5. Ongoing due diligence
Review client files on a schedule set by their risk rating, watch for transactions that do not fit the client's profile, and update identification when things change.
6. Reporting
- Suspicious matter reports within 3 business days of forming a suspicion (24 hours for terrorism financing).
- Threshold transaction reports within 10 business days of a physical cash transaction of AU$10,000 or more.
- An annual compliance report to AUSTRAC.
7. Records for 7 years
Identification records, transaction records, reports, the program and its reviews, and staff training records, kept for 7 years after the relationship ends.
And: staff training
Everyone who deals with clients must be trained when they start and kept trained. Keep a record of who was trained and when.
Questions people ask
- Which of these is the most work?
- Customer due diligence, because it repeats for every client. The program is a one-off with a yearly review; reporting is rare for most practices.
- Is there a grace period after 1 July 2026?
- No formal grace period. AUSTRAC has said it will focus on education first, but the obligations apply from the start date.
This guide is general information for accountants, bookkeepers, BAS agents, not legal advice. Check AUSTRAC's current guidance for your situation.