AML requirements for bookkeepers: what changes under Tranche 2

AML requirements for bookkeepers depend on the services provided, the customer relationship, and whether the business provides designated services under the AML/CTF framework. Bookkeepers should not assume they are automatically in or out of scope. We should start with service triage and then define the workflow.

This article is general information and is not legal advice.

Why bookkeepers need service triage

Bookkeeping businesses often sit close to company records, payroll, accounts, payments, business setup, and advisory support. Some activities may remain outside AML/CTF scope, while others may overlap with regulated services depending on the facts.

The first step is to list services and decide which require further legal or compliance review. Useful questions include:

• Do we help establish or administer companies, trusts, or other structures?
• Do we arrange authority or control over client accounts?
• Do we provide services connected to high-value transactions or funds movement?
• Do we act for overseas entities or complex ownership structures?
• Do we rely on another regulated firm, or are we responsible for our own process?

Practical AML workflow for bookkeepers

If a workflow is required, it should cover customer identity, business details, authority, ownership, purpose of service, risk factors, evidence, review, and record keeping. Small firms need a simple process, but simple does not mean informal.

Workflow step | Practical output

Service triage | A recorded decision about whether AML/CTF steps apply.

Customer profile | Individual, company, trust, partnership, or representative details.

Evidence request | Documents needed for identity, authority, ownership, or service purpose.

Risk rating | A low, medium, or high-risk outcome with rationale.

Escalation | A route for missing evidence, unusual behaviour, or ownership concerns.

Record keeping | A file showing what was collected, reviewed, approved, and retained.

How software can help

Bookkeepers do not need heavy enterprise systems, but they do need consistency. Software can help by turning service triage, evidence requests, risk rating, and approvals into a guided workflow. It can also prevent client documents, reviewer notes, and approval decisions from being scattered across email and folders.

For broader implementation guidance, read the Tranche 2 AML requirements checklist and AML software for accountants in Australia.

Frequently asked questions

Are bookkeepers covered by Tranche 2?

It depends on the services provided and the legal framework that applies. Bookkeepers should assess services, customer types, and whether any designated services are being provided.

Do bookkeepers need AML software?

No specific product is mandatory, but software can help bookkeepers manage service triage, CDD, evidence, risk review, and record keeping consistently.

Where should bookkeepers start?

Start by mapping services, then decide which client workflows require AML/CTF review, evidence collection, escalation, and retained decisions.