AML/CTF · PUBLISHED 23 SEPTEMBER 2026
Customer due diligence under the reforms
From 1 July 2026, certain professional services are subject to AML/CTF obligations. The first question is whether the specific work is a designated service.
Check whether the service is covered
AML/CTF duties depend on the services provided, not simply a business’s professional title. Map each relevant service against AUSTRAC’s guidance before setting a process for onboarding and ongoing review. A professional title or a general tax engagement does not by itself decide the answer.
Build a usable customer record
Where obligations apply, customer due diligence involves collecting and verifying information, assessing risk, and keeping records before providing a designated service where required. Procedures should address individuals, companies and trusts, including the people who own or control them where required.
Review when circumstances change
Ongoing due diligence and changes in a customer’s risk profile may call for further information or a revised assessment. AUSTRAC’s guidance also distinguishes requirements for existing customers according to when the business relationship began.
Sources: AUSTRAC — your obligations and transitioning existing customers. General information as at 23 September 2026; application depends on the designated service and applicable transitional provisions.