Three months into Australia’s Tranche 2 AML/CTF regime, the challenge for accounting firms is shifting from preparing policies and enrolling with AUSTRAC to making sure their AML framework works in practice.
The article looks at five practical areas where compliance can break down: recognising when accounting work becomes a designated service, looking beyond identity verification, documenting customer risk ratings, dealing with unusual or higher-risk cases, and ensuring responsibility for ongoing monitoring.
The key message is that effective AML compliance requires more than policies and checklists. Staff need to understand when AML obligations arise, know when to escalate issues, and apply professional judgement where circumstances do not fit neatly within established procedures.
Originally published by Accountants Daily on 1 October 2026