Are audits a designated service?
No, external audit work (financial statement audits, compliance audits, SMSF audits, AML/CTF independent evaluations) is not a designated service under the Act.
External audit work - financial statement audits, compliance audits, internal control reviews, SMSF audits, AML/CTF independent evaluations - is not a designated service. None of these activities appear in the AML/CTF Act, and audit work doesn't "directly advance" a regulated transaction; it provides assurance over what has already occurred.
The same firm may still be captured for other services it provides. An accounting firm that also incorporates companies, structures trusts, or holds client funds on the client's behalf is captured for those designated services even though its audit practice isn't.
One important note: from 1 July 2029, Tranche 2 reporting entities themselves need to commission an independent evaluation of their AML/CTF Program every 3 years. The independent evaluator (often an external auditor) is not themselves captured for performing that evaluation. See AUSTRAC's AML/CTF transitional rules update for evaluation timing.
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