AML compliance under Tranche 2: A guide for accountants & tax agents
Unriddling Tranche 2 AML compliance for accountants and tax professionals
In 2026, accounting professionals (including tax agents, BAS agents, bookkeepers and business advisors) will be subject to new AML/CTF compliance obligations.
These changes fall under what’s known as ‘Tranche 2’, the next phase of Australia’s Anti-Money Laundering and Counter-Terrorism Financing reforms. If you assist clients with financial transactions, entity structures, or fund movements, you're likely to fall within the scope of these upcoming changes.
What AML/CTF obligations apply to accountants?
While AUSTRAC’s final guidance is still being finalised, here’s what AML compliance for accountants and tax agents is expected to involve:
| Obligation | What it means |
| AUSTRAC enrolment | Register your practice with AUSTRAC by July 2026. |
| AML/CTF program | Develop a written, risk-based compliance program and regularly review and audit this. |
| KYC (Know Your Customer) | Conduct checks to verify the identity of clients and companies that you deal with when providing ‘designated services’. |
| Ongoing due diligence | Monitor client activity and reassess risk regularly. Records need to be maintained for at least seven years. |
| Reporting suspicious matters | Report activity that seems unusual or suspicious to AUSTRAC |
| Staff training | Make sure your team understands red flags and reporting steps |
Non-compliance with AML laws can result in serious penalties, even for seemingly small breaches by small practices. AUSTRAC has the authority to investigate and enforce obligations, and judging by AUSTRAC’s history, accountants won’t be exempt from scrutiny.
Why are accountants included in Tranche 2?
Accountants and tax agents often play a central role in managing client finances, structures and reporting, which can expose them to misuse by criminals seeking to hide illicit funds.
Tranche 2 reforms bring Australia into line with international AML standards by including accountants and tax agents who provide high-risk services like:
- Creating or managing companies, trusts, or partnerships
- Facilitating capital raising or debt financing transactions on behalf of clients
- Providing a registered office service for clients
How does easyAML help accountants meet their AML/CTF obligations?
We’ve heard from many that they’re feeling overwhelmed by their AML accounting compliance. easyAML is tailored for small to medium-sized firms that want a straightforward, end-to-end AML solution without the complexity.
1. Tailored onboarding for accounting professionals
- Templates and specific AML checks for accounting and tax services
- Guided risk assessment and compliance setup
- Local support from a team that understands your industry
2. Fast, accurate identity verification
- Digital KYC for individuals and businesses
- KYB tools for company directors and beneficial owners
- Secure data storage to keep client ID private
3. Tools that make compliance manageable
- Smart risk scoring to help guide you and your team
- Audit-ready reporting, aligned with AUSTRAC’s requirements
- Ongoing updates to ensure you remain compliant as rules change
Life has been much easier for both me and my clients. Verifying is quicker, even in tricky cases. Support is always responsive, and the service is second to none.
Salib Settlements
FAQs: AML for accountants & tax agents
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Will all accountants need to comply with Tranche 2?
No, only accountants providing designated services, such as forming companies or trusts, managing client funds or facilitating financial transactions, will be captured under AML/CTF obligations. However, most advisory and tax practices are expected to fall under these rules. Talk with us to confirm if your practice is impacted.
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Do bookkeepers and BAS agents need to comply with AML obligations?
Yes, if they offer designated services as outlined by AUSTRAC. This includes involvement in fund management, entity structuring, or other financial arrangements. If you’re unsure, it’s best to review your service scope now and prepare accordingly. Non-compliance may still apply even if your AML exposure is limited.
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Do I need to verify every client for AML compliance?
Yes. If your practice provides designated services, you must perform KYC checks before beginning work. This includes identity verification, risk profiling and ongoing due diligence. Failing to complete these checks could result in compliance breaches, even for longstanding or repeat clients.
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What happens if an accountant doesn’t comply with AML CTF obligations?
Non-compliance can result in financial penalties, legal action and reputational damage. AUSTRAC has the authority to issue enforcement notices and publish your firm’s name. Tranche 2 reforms are serious; your AML compliance program must meet the new standards to avoid these consequences.
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How can accountants meet their AML obligations without in-house expertise?
Using AML software (like easyAML!) helps small and medium accounting firms comply without hiring internal compliance officers. It guides you through KYC, risk assessments, monitoring and reporting, all tailored to AUSTRAC’s requirements. It’s a cost-effective way to meet obligations and avoid penalties.
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When should accounting firms start preparing for AML compliance?
Ideally, you should begin preparing by January 2026. Creating a compliant AML/CTF program takes time (typically between 3–6 months!) and involves onboarding, staff training, documentation and tool setup. Starting early with AML software ensures your accounting or tax practice isn’t rushed or exposed as the Tranche 2 deadline approaches.
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Is AML software necessary for small accounting practices?
Yes, especially for practices offering services that fall under Tranche 2. AML software simplifies compliance by automating identity checks, monitoring transactions and generating audit-ready reports. It removes the guesswork and reduces time spent managing compliance manually.
Stay ahead of Tranche 2 changes
Tranche 2 isn’t enforceable (yet), but preparation is key. Don’t wait until the last minute to get your processes in order.
Join our AML readiness list for updates, guides and tools tailored to accounting and tax practices to make your AML compliance a breeze.