Your Obligations Still Apply – Even When Using a Provider
For example, if you assist clients with setting up or restructuring a company, trust, SMSF, or other entity, you may fall within the AML/CTF regime.
Importantly, these obligations can still apply even where you engage a provider (like us) to prepare documents on your behalf.
If you’re unsure whether the requirements apply to your business, you can check your eligibility here.
What This Could Mean for Your Business
You may need to:
- Enrol with AUSTRAC
- Implement AML/CTF policies, procedures, and risk assessments
- Collect and verify client identification before work begins
- Maintain ongoing compliance records and processes
Without preparation, businesses may face onboarding delays, operational disruption, and increased compliance risk.
What We Recommend
- Review whether the services you provide could bring you within scope
- Start educating your team on what information will need to be collected
- Prepare your clients early. They may need to provide identification and other verification documents before work can proceed
If you’re unsure where to start, AUSTRAC provides practical guidance, including enrolment information and AML/CTF program starter kits. You can access these here.
We’ve also developed resources to help businesses navigate their obligations, including checklists and guides available here.
You can also access quick links to key resources on the AUSTRAC website here.
If you have any questions or would like support preparing for the changes, please don’t hesitate to reach out.
This article is prepared for general information purposes and reflects AUSTRAC’s published guidance as at March 2026. It does not constitute legal advice. The application of the AML/CTF Act depends on the specific circumstances of each entity. Practitioners are encouraged to seek independent legal advice and to consult AUSTRAC’s official guidance at austrac.gov.au to understand how the reforms apply to their particular situation.