Tranche 2 · Accountants
AML compliance that fits the way accounting firms work
Many accounting firms providing designated services — company and trust formation, managing client money, assisting with transactions, nominee roles — are reporting entities. Trancher lets you meet every obligation without a second full-time job, and record the work so it can be recovered where appropriate.
Am I captured?
Trigger is the service, not the job title.
Captured if you:
- Create, operate or manage companies or trusts
- Act as or arrange director, secretary, partner or trustee
- Provide a registered office
- Manage client money or property in a transaction
- Assist with real estate transaction planning or execution
Not every engagement is captured.
Your obligations
If you provide a designated service, you are a reporting entity. You must enrol with AUSTRAC, run a risk-based AML/CTF program, identify and monitor clients, keep records and report when the law requires it. For accounting firms that usually means company and trust work, managing client money, or helping a property or entity deal — not tax return preparation on its own.
AUSTRAC enrolment
Enrol with AUSTRAC and keep the enrolment current — including nominating a Compliance Officer. Enrolment is how AUSTRAC knows you are a reporting entity and how it contacts you.
Risk assessment
Document how your firm could be used for money laundering or terrorism financing — clients, services, delivery channels and geography — and keep that assessment current as the practice changes.
AML/CTF program
Put in writing how the firm will meet its AML/CTF duties: who does what, how clients are identified, how higher-risk work is handled, how staff are trained and how you will check the program still works.
Customer due diligence
Identify the client (and beneficial owners where relevant), verify that identity, screen for PEPs, sanctions and adverse media, and apply extra checks when risk is higher. Repeat when circumstances change.
Reporting
Submit suspicious matter reports to AUSTRAC when you form a suspicion, and any other reports that apply to your services. Do not tip the client off that a report has been made or is being considered.
Record-keeping
Keep the program, risk assessment, identification records and transaction records for at least seven years so you can show AUSTRAC what you did and why.
How Trancher helps
Maps to accounting workflows, reduces admin, supports recoverability and keeps you audit-ready.
Risk assessment and AUSTRAC-aligned program builder
Client verification (KYC/KYB) with PEPs, sanctions and adverse media screening
Ongoing monitoring and risk scoring
Reporting support (SMRs)
Staff training modules
Audit-ready records and dashboard
Three clear paths
Choose the level of support that works for your firm — manage compliance yourself, add expert support when you need it, or have agreed activities managed for you.
1
Self-managed
Run your AML program through Trancher using clear workflows and built-in guidance.
From $9.99 per week.
2
Self-managed + expert support
Use the platform day to day and bring in our compliance specialists when you need help with set-up, risk assessment, program development, onboarding, training or first files.
3
Fully managed by our experts
Ask our experienced compliance specialists to manage agreed AML compliance activities on your organisation’s behalf.
How long does it take?
Most firms move from start to operational compliance within weeks.
Days 1–7
Enrolment and risk assessment underway
Days 8–21
Workflows live and team trained
Thereafter
Fully operational and audit-ready
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Am I captured?
Trigger is the service, not the job title. You may be captured if you create, operate or manage companies or trusts; act as or arrange a director, secretary, partner or trustee; provide a registered office; manage client money or property in a transaction; or assist with real estate transaction planning or execution. Not every engagement is captured — routine tax return or BAS work alone does not trigger obligations.
What are the deadlines?
Tranche 2 obligations commenced on 1 July 2026. Firms already providing designated services on that date needed to enrol with AUSTRAC by 29 July 2026. If you start providing a designated service later, enrol within 28 days of first providing it. Nominate an AML/CTF Compliance Officer and keep your enrolment current.
What goes in the program?
Your AML/CTF program must include a written risk assessment of how your practice could be used for money laundering or terrorism financing (clients, services, delivery channels and geography) plus the policies, procedures, systems and controls to manage those risks. For accounting firms this typically covers client identification, beneficial ownership, PEPs/sanctions/adverse media screening, ongoing monitoring, suspicious matter reporting, staff training and record-keeping — tailored to the designated services you actually provide (company/trust work, managing client money, property or entity deals).
What does CDD look like in practice?
Identify the client (and beneficial owners where relevant), verify identity from reliable independent sources, and screen for PEPs, sanctions and adverse media. Apply enhanced checks for higher-risk clients or services, and update when circumstances change. In practice this most often arises on company or trust formation/restructuring, when managing client money or property in a transaction, or assisting with a property or entity deal — not on routine tax or compliance work alone. Records travel with the client file.
How is KYC/KYB charged?
Every verification check triggers one transaction. If you are identifying individuals within an entity (for example directors, beneficial owners or authorised persons), each individual check is a separate transaction and is charged accordingly.
Disclaimer
This is a plain-English guide only and is not a determination of your firm’s status. Whether you are a reporting entity depends on the specific designated services you provide, the facts of each engagement, and the applicable items in the AML/CTF Act. If unsure, use the Am I in scope? guide or seek independent legal advice. Trancher does not provide legal advice.
Ready to simplify compliance?
Book a short overview or speak with our in-house specialists about the right path for your firm.