Bookkeepers can be caught by the AML/CTF Tranche 2 reforms where their work involves managing or controlling client money, accounts or other assets. From 1 July 2026, providing such a designated service makes a business a reporting entity with AUSTRAC obligations.
Pure data-entry bookkeeping with no control over client funds is generally lower risk. But the moment you operate client accounts, move money, or hold assets on a client's behalf, you should check your status carefully.
Designated services for bookkeepers
If you provide any of these, you're likely a reporting entity:
- 1Managing client money, accounts, securities or other assets
- 2Operating or controlling a client's bank accounts on their behalf
- 3Assisting to plan or execute the transfer of money or other assets
- 4Holding client funds in trust or controlled-money arrangements
What you'll need to do
- 1Enrol with AUSTRAC (enrolment opened 31 March 2026)
- 2Appoint an AML/CTF Compliance Officer
- 3Complete a money-laundering / terrorism-financing risk assessment
- 4Develop and maintain an AML/CTF program
- 5Carry out customer due diligence (KYC) and verify beneficial owners
- 6Monitor transactions and report suspicious matters, large cash transactions and international transfers
- 7Keep records for seven years and train your staff
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Check your exact obligations
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