AML/CTF program for accountants: how to prepare before 1 July 2026
An AML/CTF program for accountants should explain how the firm identifies ML/TF risks, manages those risks, conducts customer due diligence, trains staff, reports suspicious matters, keeps records, and reviews controls. For Tranche 2, the program must also translate into real client workflows.
This article is general information and is not legal advice.
Start with accounting services, not a template
Templates help structure the work, but accounting firms should begin with their actual services. Company formation, trust support, advisory work, SMSF support, transaction-related services, business structuring, and routine tax work may require different decisions.
A practical program should state which services are in scope, which are out of scope, and which require compliance review before the firm proceeds. That scope decision should become part of the client file.
CDD procedures | Define evidence for individuals, companies, trusts, SMSFs, partnerships, and foreign entities.
EDD triggers | Escalate high-risk jurisdictions, PEP indicators, complex structures, and unresolved ownership gaps.
Reporting pathway | Define who reviews suspicious indicators and how staff escalate concerns.
Training | Teach staff workflow decisions, not only AML vocabulary.
Records | Retain evidence, risk rating, reviewer notes, approvals, and ongoing review history.
Make the program operational
The program should be tested against real accounting client patterns. We should run a low-risk individual, a proprietary company, a trust, an SMSF, a foreign shareholder, and a client with missing beneficial ownership evidence. If the program cannot guide staff through those cases, it needs more operational detail.
Software helps by turning the program into guided workflows. The firm can request documents, route exceptions, calculate risk, assign reviewers, and keep an audit trail without relying on inbox memory.
How Veraxa helps
Veraxa helps accounting firms convert an AML/CTF program into client onboarding, beneficial ownership, risk rating, review, approval, and monitoring workflows. Continue with AML software for accountants in Australia, AML/CTF software for accountants, or the accountants solution page.
Frequently asked questions
Do accountants need an AML/CTF program?
Accounting firms that provide regulated designated services may need an AML/CTF program. Firms should assess their services and obligations with qualified advisers.
What should the program include?
It should include governance, risk assessment, CDD, EDD, reporting, training, record keeping, and review procedures.
How does software support the program?
Software helps staff apply the program consistently by guiding intake, evidence collection, risk rating, escalation, approval, and monitoring.