Tranche 2 AML/CTF Compliance for Accountants and Tax Agents

From 1 July 2026, Australian accounting practices providing designated services must comply with AML/CTF Tranche 2 requirements.

If you provide any of these services, you become a reporting entity:

• Buying and selling real estate

• Managing client money, securities, or other assets

• Managing bank, savings, or securities accounts

• Organizing contributions for company formation, operation, or management

• Creating, operating, or managing trusts and companies

Standard tax return preparation and bookkeeping services alone typically don't trigger these requirements.

Not quite. TPB compliance provides an excellent foundation, but AML/CTF adds specific requirements:

• Formal risk classification systems (low/medium/high)

• Beneficial ownership mapping beyond client representatives

• PEP and sanctions screening

• Source of wealth/funds verification for high-risk clients

• Ongoing transaction monitoring

• Mandatory reporting to AUSTRAC (SMRs and TTRs)

Most likely! Your TPB verification satisfies many AML/CTF requirements when:

• Your DVS verification meets identity confirmation standards

• Authority documentation covers representative verification

• Record-keeping provides audit trail foundation

• Risk assessment aligns with AML/CTF methodology

You'll need to add: formal risk classification, PEP/sanctions screening, enhanced due diligence procedures, broader beneficial ownership mapping, ongoing monitoring systems, and reporting capabilities.

CDD is the process of identifying and verifying your client's identity, understanding their ownership structure, assessing their money laundering/terrorism financing risk, and monitoring the relationship throughout its duration.

A PEP is an individual who holds or has held a prominent public function. This includes heads of state, senior politicians, senior government officials, judicial or military officials, senior executives of state-owned corporations, and important political party officials.

Three main reports:

1. Suspicious Matter Reports (SMRs): When you suspect money laundering, terrorism financing, sanctions breaches, fraud, or unusual transactions

2. Threshold Transaction Reports (TTRs): When you receive AUD $10,000 or more in cash or cash equivalent in a single transaction

3. Annual AML/CTF Compliance Report: Due 31 March annually, covering the previous calendar yearem description

Not necessarily. If your existing TPB verification meets AML/CTF standards, you can leverage that work. However, you'll need to add risk classification, PEP/sanctions screening, and beneficial ownership mapping for clients receiving designated services.

Non-compliance can result in significant penalties from AUSTRAC, including substantial fines, enforcement actions, and potential criminal liability for serious breaches.

Not with shareable credentials. If your client's identity is verified once through a compliant system like VerifiMe, those verified credentials can be securely shared with their accountant, lawyer, mortgage broker, and financial advisor—eliminating duplicate verification.

While you could manage compliance manually, most practices will benefit from dedicated AML/CTF compliance software that automates risk assessment, PEP/sanctions screening, ongoing monitoring, and reporting.

VerifiMe automatically maps your existing TPB verification to AML/CTF requirements, adds the additional screening and risk assessment needed, and creates audit-ready documentation for both frameworks—all without re-verifying clients.