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Do bookkeepers and BAS agents with access to client bank accounts need to register?

Operational bank-account access is not itself a designated service, but holding or transferring client funds for specific transactions can be.

Overview

It depends on what the bookkeeper or BAS agent actually does with client funds. Routine bookkeeping - BAS preparation, payroll processing, management reporting, and operational access to a client's bank account to process routine payments - is not a designated service. The position changes when funds are held or controlled for a specific transaction.

When it becomes a designated service

You may be providing a designated service (and so need to register) where you:

  • Receive, hold or control client funds as part of a specific transaction (e.g. holding a deposit for an asset purchase, managing settlement proceeds, processing one-off third-party payments)
  • Act as a nominee or trustee in a client structure
  • Provide the activity within a wider service offering that includes trust or company structuring (Table 6, items 4-6)
  • Have authority over a client's bank account to make payments on their behalf, e.g. loan repayments to a financier
  • Prepare an ABA file and execute payment (with or without the client's joint authority) for rent or other business expenses, excluding employee entitlements

Activities that are NOT designated services

Holding client money on trust as payment for your own services; preparing payroll and the ABA file (including uploading it for the client to execute, or executing it on their behalf); preparing the ABA file for rent or other business expenses excluding employee entitlements; preparing an SMSF tax return; receiving a tax refund into your trust account and disbursing it to the client; preparing and lodging BAS; providing tax advice on selling a company; completing an ATO clearance certificate application to avoid Foreign Resident Capital Gains Withholding.

The distinction in short

Managing funds for payroll is not in scope; managing funds for transaction-specific purposes may be. A bookkeeper running monthly payroll isn't a reporting entity for that activity; one holding client funds during an asset sale may be. The Institute of Public Accountants has a useful technical resource ("AML/CTF Tranche 2: Do you need to comply?"). If the practice mix isn't clear, review the service offering against the designated services list in Tables 5 and 6 of the AML/CTF Act, or ask your BDM to escalate to compliance for a sector-specific assessment. See AUSTRAC's Professional designated services page.

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