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Which accounting firm activities are designated services under Tranche 2?

Lists the specific accounting practice activities that trigger AML/CTF obligations, focused on accountants actively facilitating transactions or structures.

AML/CTF Tranche 2 obligations do not apply to the whole accounting profession. They apply to specific activities. Whether a practice is captured depends on what it actually does, not what it calls itself or the type of clients it typically serves.

The underlying logic of Tranche 2 is that professional services can be misused to obscure the origin or ownership of funds or assets. The activities captured are those where the accountant is actively facilitating or implementing a transaction or structure, rather than providing advice in isolation. Whether a designated service is provided turns on the specific circumstances of the engagement, including whether the accountant's actions are sufficiently linked to advancing the outcome (such as a transaction) and whether any exception applies. Common in-scope examples include setting up companies and SMSF corporate trustees, drafting or reviewing trust deeds and corporate agreements, executing payments with authority over a client's account, and providing a registered office address.

Where an accounting firm provides designated services, the AML/CTF obligations from 1 July 2026 include:

  • Enrolling with AUSTRAC.
  • Assessing ML/TF risks and developing an AML/CTF Program.
  • Appointing an AML/CTF Compliance Officer.
  • Conducting due diligence on workforce and providing AML/CTF training.
  • Conducting initial CDD on clients, including identity verification and beneficial ownership.
  • Conducting ongoing due diligence and transaction monitoring.
  • Meeting internal and external reporting obligations, including suspicious matter identification, assessment and reporting (SMRs).
  • Maintaining records of activities and compliance.

The nine items below set out the designated services in Table 6 of the AML/CTF Act as they apply to accounting practice, with the typical activities that are in scope and those that sit outside.

Item 2 - Buying or selling a body corporate or legal arrangement

Designated services:
- using an online company service to set up a company
- undertaking due diligence, including valuing the assets and liabilities, for the sale of a client's company
- preparing or reviewing a Vendor's (section 52) Statement for the sale of a company
- preparing the forms to be submitted to ASIC to transfer a company
- drafting, reviewing or negotiating agreements or business documents to create or restructure a company (e.g. company constitutions, partnership agreements or shareholder agreements); representing a client in negotiations to buy or sell a company
- drafting, reviewing or negotiating agreements or business documents for a client's company merger or demerger (including a proposed merger or demerger).

Not designated services:
- sale and purchase of minor interests (generally less than 25% of the shares or other interests in the company or legal arrangement)
- purely advising on deal-structure options without executing transfers; court-ordered transfers.

Item 3 - Receiving, holding, controlling or managing property (usually funds)

Designated services:
- holding property in escrow
- managing escrow funds to enable a transaction
- receiving, holding and transferring client funds through the firm's trust account as part of a transaction
- having authority for a client's bank account and making transactions on their behalf.

Not designated services:
- operating a trust account where no designated service is being provided (e.g. running a trust account for a practice that only provides traffic-law advice).
- holding or receiving funds in the trust account for prepayment of the firm's services; for use, maintenance, repair or oversight of property
- for payment under a court or tribunal order (e.g. reviewing a judgement sum for a client)
- when receiving funds from government, courts, tribunals, insurers and certain other specified entities.

Item 4 - Assisting in organising, planning or executing equity or debt financing involving a body corporate or legal arrangement (including proposed ones)

Designated services:
- drafting and executing loan documents for a company
- drafting equity fundraising documents (IPOs, venture capital, share purchase plans, etc.)
- coordinating drawdowns on a financing arrangement
- working to execute a financing transaction.

Not designated services:
- providing general or strategic advice on financing options (debt or equity)
- preparing options presentations or papers and discussing options
- arranging finance for an individual in their own capacity, including when the financier is a body corporate or legal arrangement.

Item 5 - Assisting a person in selling or transferring a shelf company in the course of a business

Designated services:
- facilitating the transfer of a company that the practice pre-incorporated. This typically occurs in the course of a business that establishes shelf companies and then offers them for sale.

Not designated services:
- strategic advice such as assisting with decisions to acquire a company that has not traded
- arranging for someone else to incorporate a company for a client where the client will be shareholder and director
- providing administrative services to apply to ASIC to register a company for a client (where the client is the shareholder and director and the firm has not given planning or structuring advice).

Item 6 - Assisting in creating or restructuring a body corporate or legal arrangement

Designated services:
- preparing documents in anticipation of creating a body corporate or legal arrangement (drafting, reviewing or negotiating corporate agreements and business documents)
- drafting and reviewing trust deeds in relation to the creation or restructure of a trust
- drafting documents to create an association or co-operative
- lodging company and business-name applications and forms with ASIC where the firm has provided planning or structuring advice
- applying for regulatory approvals and waivers (ASX, ASIC, FIRB)
- conducting due diligence in respect of a transaction.

Not designated services:
- purely advisory work, for example high-level organisational structure advice without preparing any instruments and without a transaction
- dealing with operational, IT and other management functions; drafting a will, even where it includes the subsequent creation of a testamentary trust
- creating or restructuring a corporation under the Corporations (Aboriginal and Torres Strait Islander) Act 2006 (Cth).

Item 7 - Acting in or arranging specified roles (directors, powers of attorney for non-natural persons, partners, etc.)

Designated services:
- acting as company director on behalf of a customer, or arranging for someone to act in a specified role - director, secretary, power of attorney, partner or trustee.

Not designated services:
- acting for a natural person under a power of attorney
- acting under a court-appointed fiduciary role
- acting as trustee of a regulated debtor's estate, including as trustee of a testamentary trust.

Item 8 - Acting as or arranging a nominee shareholder of a body corporate or legal arrangement on behalf of someone in the course of a business

Designated services:
- identifying or arranging a person to act as a nominee shareholder
- holding shares on behalf of another under instruction
- arranging a nominee shareholder to act for a client.

Not designated services:
- purely advising on nominee structures without acting as nominee
- acting as a nominee solely due to a court order.

Item 9 - Providing a registered office or principal place of business

Designated services:
- providing the firm's address as the registered office of a client company.

Not designated services:
- providing office space unrelated to a registered office (e.g. permitting a client to use offices for meetings or administrative support)
- providing a postal address that is not the client's registered office or principal place of business.

Important: the items above set out the typical patterns under each Item of Table 6. They are general guidance, not a determination - whether a specific activity is a designated service depends on the actual conduct and the surrounding facts. For matters where the position is unclear, the firm should consider obtaining independent legal advice before assuming a service sits inside or outside scope.

For accoutants, AML/CTF compliance represents a shift in professional risk management rather than a purely technical exercise. It introduces expectations around structure, consistency and documentation in areas of practice that have traditionally relied heavily on individual judgement. Done well, it supports clearer client understanding, sharper engagement boundaries and stronger internal controls alongside meeting the regulatory requirements.

See AUSTRAC's Professional designated services page.

Related entries:

  • Are audits a designated service? (external assurance work)
  • Is tax-return preparation a designated service? (administrative tax work)

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