David Boyar
With less than 90 days until Australia’s AML/CTF Tranche 2 reforms take effect, leading software provider The Access Group is calling on accounting practices to act immediately – while urging AUSTRAC and peak professional bodies to accelerate practical, profession-specific guidance before the window closes.
The reforms will bring approximately 80,000 new entities under the Anti-Money Laundering and Counter-Terrorism Financing regime from 1 July 2026, joining around 15,000 already regulated businesses.
For accounting practices, this represents the most significant compliance transformation since GST was introduced in 2000.
“The firms that treated GST as a ‘we’ll figure it out’ problem were the ones scrambling in August 2000. History is about to repeat for anyone not moving now,” David Boyar FCA (The Access Group).
What the new operating model actually requires
The Access Group is emphasising to the profession that this is not a documentation exercise. Before 1 July, every practice providing designated services must have all of the following in place, with all staff trained in how to comply:
- a written AML/CTF Program
- a designated AML/CTF Compliance Officer
- a risk assessment framework covering all designated services
- customer Due Diligence (CDD/KYC) workflows for every client
- ongoing transaction monitoring capability
- suspicious Matter Reporting (SMR) procedures
- staff training completed and recorded.
Firms that have not yet enrolled with AUSTRAC – which opened enrolment in late 2025 – are already behind. Non-enrolment carries a civil penalty of 60 penalty units per day for body corporates: $18,780 per day under current indexation, rising further from 1 July. Serious or willful non-compliance carries a maximum civil penalty of $31.3 million.
The guidance gap
AUSTRAC has published starter kits, factsheets, and a webinar series. The intent is welcome, but the limitation is real. There is no single, authoritative source that tells a two-partner accounting firm – step by step, service by service, client by client – exactly what to do.
Existing guidance is largely written for financial institutions. What accountants need is scenario-based guidance grounded in actual accounting practice contexts: what a Suspicious Matter Report looks like for a firm that suspects a client is structuring payments to avoid tax obligations, not a hypothetical bank transaction.
The Access Group is calling on CPA Australia, Chartered Accountants ANZ, and the IPA to match the urgency of the deadline. Their members – the very practitioners now facing the heaviest compliance uplift – need coordinated, urgent communication and worked examples, not another checklist, and it’s on the major professional bodies to lead this support.
“This is the latest in a cumulative burden on small practices, and the timeframe for compliance compounds an already significant challenge,” according to David Boyar, FCA (The Access Group).
“The expanded TASA obligations – eight new Code of Professional Conduct requirements – only took full effect for most practices on 1 July 2025. Twelve months later, the same firms must stand up an entirely separate compliance regime.
“Two fundamental reforms to how accountants engage with clients, back-to-back. For small practices with no dedicated compliance resource, the operational pressure is acute. Paper-based processes and manual workflows are not a viable answer.”
A purpose-built solution for the Australian accounting profession
The Access Group has developed EngageAML to address this challenge. Built specifically for accounting practices – not adapted from a financial services platform – EngageAML automates the full AML compliance workflow:
- identity verification and biometric checks embedded into client onboarding
- PEP (Politically Exposed Person) and sanctions screening
- automated risk assessment and scoring
- ongoing transaction monitoring with exception alerts
Suspicious Matter Report drafting support - compliance program documentation and audit trail
- integrated AML and KYC checks into the Engagement letter combining AML and TASA regulatory obligations in one workflow.
The platform is purposely designed around the workflows accounting practices are already running, so compliance becomes part of the engagement process rather than a separate workstream. Client onboarding time is significantly reduced compared to manual approaches.
“The compliance officer role in a small firm only works if technology does most of the heavy lifting,” said David Boyar FCA at The Access Group. “Flagging risk, prompting reviews, maintaining records, generating reports — that is what the platform does. The partner makes the judgement calls.”
Immediate actions practices should take:
- enrol with AUSTRAC immediately if not already done
- appoint a designated AML/CTF Compliance Officer
- commission or purchase an AML/CTF risk assessment
- begin drafting your written AML/CTF Program
- audit your client base for designated service obligations.
- implement a CDD workflow before 1 July — manual or technology-assisted.