**Published by WNR Business Consulting | July 2026**
Australia’s expanded anti-money laundering and counter-terrorism financing requirements now apply to certain professional services provided by accountants, tax agents, lawyers and company and trust service providers from **1 July 2026**.
The changes are designed to prevent companies, trusts and professional services from being misused for money laundering, tax evasion, terrorism financing and other serious criminal activities. ([AUSTRAC][1])
## Which Accounting and Tax Services Are Affected?
The AML/CTF requirements are based on the **type of service provided**, rather than simply applying to every accountant or tax agent engagement.
Services that may be regulated include:
* establishing or restructuring a company, trust or other legal arrangement;
* assisting with the purchase, sale or transfer of a company, trust or business structure;
* selling or transferring a shelf company;
* arranging for a person to act as a director, company secretary, trustee or nominee;
* providing a registered office or principal business address;
* assisting with equity or debt financing arrangements; and
* receiving, holding, controlling or managing property in connection with certain transactions. ([AUSTRAC][2])
Company incorporation and trust establishment services are therefore among the activities most likely to trigger the new requirements.
Routine tax return preparation is not specifically listed as a professional designated service. However, a tax agent may become subject to AML/CTF obligations where the engagement also includes company formation, restructuring, business acquisitions, financing arrangements, registered office services or another designated activity. This is a service-by-service assessment. ([AUSTRAC][2])
## What Will Change When Setting Up a Company?
Before WNR Business Consulting can proceed with a regulated company establishment or restructuring service, we may need to complete customer due diligence.
This involves establishing the identity of the client and understanding:
* who is requesting the company setup;
* who will own and control the company;
* the identity of directors, shareholders and beneficial owners;
* whether anyone is acting on behalf of another person;
* the intended activities and purpose of the company; and
* the money laundering and terrorism financing risk associated with the engagement.
Initial customer due diligence must generally be completed before the designated service begins. Customer information must also be monitored and kept up to date throughout the business relationship. ([AUSTRAC][3])
## Information New Clients May Be Asked to Provide
Depending on the client and the services requested, WNR Business Consulting may ask for:
* a passport or driver licence;
* current residential address details;
* company or business registration information;
* details of directors, shareholders and beneficial owners;
* trust deeds and information about trustees, appointors and beneficiaries;
* an explanation of the proposed business activities;
* the reason for establishing the entity;
* information about the source of funds used for the transaction; and
* information about the client’s source of wealth in higher-risk circumstances.
Identity information may be verified in person, through a video meeting or by an approved electronic verification process using reliable and independent information. ([AUSTRAC][4])
A request for identity or source-of-funds information does not mean that the client is suspected of wrongdoing. These checks are part of the compliance procedures that regulated professional firms must follow.
## Beneficial Ownership Checks
It is no longer sufficient to identify only the person who contacts the accounting firm.
Where a company, partnership, association or trust is involved, the firm must also determine the individuals who ultimately own or control the structure. This may require reviewing company records, trust deeds, shareholder information and ownership arrangements. ([AUSTRAC][5])
Additional checks may be required where:
* the ownership structure is unusually complex;
* nominee shareholders or directors are involved;
* the client is based overseas;
* the client has connections to a higher-risk country;
* the client is a politically exposed person;
* the information provided is inconsistent; or
* the purpose of the structure is unclear.
## Source of Funds and Source of Wealth
For higher-risk clients or transactions, WNR Business Consulting may need to establish how the funds used in a transaction were obtained.
A source of funds enquiry looks at the origin of money used for a particular transaction, such as:
* salary or business income;
* investment earnings;
* a bank loan;
* proceeds from selling property;
* an inheritance; or
* a gift.
A source of wealth enquiry considers how the client accumulated their overall wealth. Supporting evidence may include bank statements, sale contracts, financial statements, loan documents, tax records or estate documentation. ([AUSTRAC][6])
## Reporting Suspicious Matters to AUSTRAC
Accountants providing designated services must submit a suspicious matter report where they form a suspicion on reasonable grounds that:
* a client or prospective client is not who they claim to be;
* information may be relevant to criminal activity;
* tax evasion or another offence may be involved; or
* a person may be planning to use a designated service for money laundering or terrorism financing.
A report may be required even where the firm decides not to accept the client or does not proceed with the requested service. ([AUSTRAC][7])
Suspicious matter reports must generally be submitted:
* within **24 hours** where the suspicion relates to terrorism financing; or
* within **three business days** for other suspicious matters. ([AUSTRAC][7])
The firm may be legally restricted from telling a client that a suspicious matter report has been made where disclosure could prejudice an investigation. This is commonly known as the **tipping-off prohibition**. ([AUSTRAC][8])
## Other Reporting and Record-Keeping Requirements
Depending on the services and transactions involved, a reporting entity may also have obligations relating to:
* physical cash transactions of **$10,000 or more**;
* certain instructions to transfer funds into or out of Australia;
* annual AML/CTF compliance reporting; and
* maintaining customer due diligence, transaction and AML/CTF program records.
Relevant AML/CTF records generally need to be retained securely for seven years. ([AUSTRAC][9])
## How WNR Business Consulting Can Assist
WNR Business Consulting provides professional assistance with:
* company and trust establishment;
* business and investment structuring;
* tax agent engagement and client onboarding;
* beneficial ownership reviews;
* director and shareholder registrations;
* ASIC, ABN, TFN and GST registrations;
* business acquisitions and restructuring; and
* ongoing accounting and taxation compliance.
Our updated onboarding procedures are designed to meet Australia’s AML/CTF requirements while making the company setup and tax engagement process as straightforward as possible.
**WNR Business Consulting**
**Eugene Dou CPA – Registered Tax Agent**
Phone: 0402 500 543
Email: [eugene.dou@wnrbc.com.au](mailto:eugene.dou@wnrbc.com.au)
Website: [www.wnrbc.com.au](http://www.wnrbc.com.au)
*Disclaimer: This article provides general information only and does not constitute legal, taxation or financial advice. Whether the AML/CTF legislation applies depends on the particular services provided and the circumstances of each engagement.*
[1]: https://www.austrac.gov.au/industry-and-business/about-amlctf-reforms/about-reforms?utm_source=chatgpt.com “About the AML/CTF reforms”
[2]: https://www.austrac.gov.au/new-austrac/designated-services-newly-regulated-entities/professional-designated-services “Professional designated services | AUSTRAC”
[3]: https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/customer-due-diligence/overview-customer-due-diligence “Overview of customer due diligence | AUSTRAC”
[4]: https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/customer-due-diligence/initial-customer-due-diligence/initial-customer-due-diligence-guides-customer-type/initial-cdd-individuals?utm_source=chatgpt.com “Initial CDD for individuals”
[5]: https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/additional-guidance/determining-ownership-and-control-structures?utm_source=chatgpt.com “Determining ownership and control structures”
[6]: https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/customer-due-diligence/source-funds-and-source-wealth?utm_source=chatgpt.com “Source of funds and source of wealth”
[7]: https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/reporting-us/suspicious-matter-reports “Suspicious matter reports | AUSTRAC”
[8]: https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/reporting-us/tipping?utm_source=chatgpt.com “Tipping off”
[9]: https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-obligations “Your obligations | AUSTRAC”