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The next wave of AML changes is coming

Ready for Tranche 2 reforms? Navigating customer due diligence, governance workflows and record-keeping for designated entities.

ABN, BAS, COGS — if you’re an accountant, you’re used to using a whole alphabet of acronyms. Thanks to Tranche 2 of the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) framework, you may need to learn some new ones.

Tranche 2 broadens the services covered by the AML/CTF framework, which means that more accounting practices and financial organisations will be affected. Under the framework, these designated entities must follow rules around customer due diligence, transaction monitoring, record-keeping and reporting. More than just new acronyms, it’s a whole new set of rules that your practice will need to navigate.

There’s a lot to make sure you have covered to meet your new obligations. Here’s some background on what needs to be done and how the MYOB ecosystem can help.

AML/CTF Tranche 2 – Key changes

The AML/CTF framework is designed to track, catch, and deter financial crimes. It does this by requiring financial service organisations — like accountants and real estate agencies — to gather information about their customers, track transactions, and report back to AUSTRAC, the government body that oversees the framework.

While the AML/CTF Act has been in place since 2006, it's scope is increasing to cover more industries to bring it in line with international guidelines. From 1 July 2026, professional services firms that provide certain services will have new regulatory obligations.

Note: This is general information only; MYOB can’t offer legal or regulatory advice.

A broader scope, more reporting entities

Tranche 2 includes a broader definition of AML/CTF reporting entities, which is the change most likely to impact accountants and bookkeepers.

Under the current rules, banks, currency exchangers, casinos and other financial services providers are considered reporting entities that need to comply with AML/CTF obligations. When Tranche 2 comes in, any company that provides Table 6 Professional Services, referred to as designated services, will be considered a reporting entity.

Table 6 Professional Services relate to real estate, business entity transactions, client assets or funds, financing, entity creation and restructuring, or acting on behalf of a client in several scenarios. While most tax return and bookkeeping services don’t fall under the Table 6 banner, activities like advisory, structuring and entity administration do.

It’s up to each practice to work out whether they provide designated services under AML/CTF. Not sure whether your practice is included? Use this AUSTRAC tool to check.

Understanding your AML/CTF obligations

What does it mean if your practice will be a reporting entity when Tranche 2 requirements come in? From 1st July, you’ll be required to meet AML/CTF obligations.

This means registering with AUSTRAC as a reporting entity and creating your own AML/CTF program, including risk assessment, detection and mitigation frameworks. You’ll also be required to follow customer due diligence (CDD) guidelines, monitor transactions and customer activity, and report suspicious activity to AUSTRAC.

MYOB: Supporting your AML/CTF transition

Creating a risk assessment program, tracking transactions, following stringent CDD rules; if your practice hasn’t needed to deal with AML/CTF compliance before, the new obligations may seem overwhelming. The good news: There’s plenty of support available from many sources, but start with this detailed guidance from AUSTRAC.

MYOB helps by being the source of truth for your client data and integrating with specialist AML tools. However, MYOB doesn’t cover other obligations, like AML transaction monitoring, PEP screenings or AUSTRAC reporting.

Here’s how our solutions can help:

Tracking, document management and workflow with MYOB AE and AO

MYOB Accountants Enterprise and Accountants Office gather data and streamline work in busy accounting practices. Both products can contribute to your AML/CTF compliance by storing records and documents, configuring workflows, and giving your team a single source of truth for client information.

Your practice could use your AE or AO product with our integration with AML service providers to:

  • Store client information, including identities, addresses, roles and relationships, so you have a clear record for relevant AML/CTF clients.

  • Collect and retain documents, including engagement letters, ID, CDD documentation, risk assessments, file notes and AML policies.

  • Act as a searchable, long-term archive for client records, which must be stored for seven years.

  • Create specific workflows for client onboarding, transaction reviews and other AML/CTF tasks, complete with task flows and approvals. This ensures that the right information is collected and stored every time.

  • Track client checks and information to support CDD obligations.

You can use external AML and KYC platforms to make sure you meet all your obligations. MYOB is just one piece of the puzzle.

From onboarding to reporting with MYOB Practice Management

MYOB Practice Management (MPM) also has client management, KYC features and AML integrations that can help practices meet their obligations.

Your practice could use MPM to:

  • Collect client details and entity information through the self-service onboarding portal.

  • Record and manage client information and relationships using the built-in CRM function.

  • Collect proof of identity (PoI) information, record document sighting, and verify using external sources.

  • Create job templates and plans for AML/CTF tasks like client onboarding and annual review. You can include steps like beneficial owner checks, risk-rating and approvals.

  • Add alerts to review high-risk clients regularly.

  • Use an integrated document management system to store and search KYC information, risk assessments, SMR logs and any policy documents linked to clients.

  • Monitor and assess clients according to industry, geography, partner organisations and other risk factors, for easier AUSTRAC reporting.

MPM integrates with specialist AML providers, so you can add tasks like digital ID verification and AML screening to your onboarding workflow.

Your AML/CTF to-do list

With Tranche 2 on the horizon, what does your practice need to do?

Here’s a look at the first five steps for new reporting entities:

  1. Find out whether you are in scope and register with AUSTRAC.

  2. Create a customised AML/CTF program — the AUSTRAC Starter Kit can help you get started.

  3. Configure your AE, AO or MPM platform to capture CDD data in your onboarding process, and create workflows to review high-risk clients.

  4. Integrate specialist AML and KYC tools to feed data back to your existing system — you may need help from your IT team or MYOB to do this.

  5. Train staff in best practices for AML/CTF compliance, including data collection, risk assessment, AUSTRAC reporting and record-keeping.

Need help? The AUSTRAC Accountants Hub is a trove of useful information and step-by-step guides, while MYOB can offer support around workflows and integration. Reach out to us if you want more information on how to use MYOB products to meet your AML/CTF obligations. Get in touch now.

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Information provided in this article is of a general nature and does not consider your personal situation. It does not constitute legal, financial, or other professional advice and should not be relied upon as a statement of law, policy or advice. You should consider whether this information is appropriate to your needs and, if necessary, seek independent advice. This information is only accurate at the time of publication. Although every effort has been made to verify the accuracy of the information contained on this webpage, MYOB disclaims, to the extent permitted by law, all liability for the information contained on this webpage or any loss or damage suffered by any person directly or indirectly through relying on this information.

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