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AML/CTF staff training for accounting practices.

If an accounting practice provides a table 6 designated service, AML/CTF obligations apply from 1 July 2026, and everyone who does AML/CTF work needs training that fits their role. Whether a task is regulated depends on the facts, so partners and compliance officers need the deepest tracks.

Sources for this answer
  • AUSTRAC: "AML/CTF obligations apply if you provide a designated service in table 6 from 1 July 2026." Whether your work is such a service "depends on the facts of each case". [S9]
  • AUSTRAC: for lawyers, accountants, conveyancers, insolvency practitioners, financial advisers or professional services there is a separate guide on the designated services they provide. [S7]
  • AUSTRAC: "You must provide initial training at the start of a person’s employment or engagement. You must also provide ongoing training." [S1]

Who in a practice needs which track?

  • Partners and directors who approve the program: senior manager track.
  • The AML/CTF compliance officer: compliance officer track.
  • Accountants and bookkeepers who onboard or advise clients: front-line track.
  • Support staff who open files or process payments: all-staff track at least.
Facts and sources for this part
  • AUSTRAC: "A senior manager is an individual who makes, or is involved in making, decisions affecting all or a substantial part of your business." [S20]
  • AUSTRAC: "All personnel in customer-facing roles need an awareness of indicators of suspicious activity and your reporting procedures." [S1]

What does AUSTRAC list as accountant red flags?

  • A client who does not seem to understand the business sector they say they work in.
  • A client who ends the relationship after you ask for more information.
  • A client who appears to be following instructions from third parties.
Facts and sources for this part
  • AUSTRAC accountant red flags: a client who "doesn’t seem to understand the business sector they’re operating in", "ends the relationship after you ask for more information" or "appears to be following instructions of third parties". [S38]
  • AUSTRAC: "Your professional services are an easy target for illicit activities." [S38]

What if the work is not a designated service?

AUSTRAC says the answer depends on the facts of each case. Staff should still learn the red flags, because the person at the front desk may be the first to see them.

Facts and sources for this part
  • AUSTRAC: "AML/CTF obligations apply if you provide a designated service in table 6 from 1 July 2026." Whether your work is such a service "depends on the facts of each case". [S9]

Which lessons fit?

All tracks start with the duty and red flags. Compliance officers and partners add the program lesson.

  1. Lesson 1The training duty, and what it means for you3 min
  2. Lesson 3Red flags in your sector3 min
  3. Lesson 4Suspicious matter reports and tipping off3 min
  4. Lesson 6Your AML/CTF program, officer and senior managers3 min
Facts and sources for this part
  • AUSTRAC: a senior manager "will still need to be able to meet their AML/CTF obligations and receive appropriate training". [S20]