The 1 July 2026 deadline is approaching fast. Whether you’ve been actively preparing or are just starting to think about it, here’s a practical five-step checklist to get your practice ready.
Step 1: Understand which services trigger obligations
Not every service you provide will be a “designated service” under the AML/CTF Act. Start by mapping your service offerings against the legislation to understand exactly which parts of your practice are in scope.
Key question: Do you manage client funds, form companies, provide a registered office address or administer trusts? If yes, you’re almost certainly in scope.
Step 2: Appoint an AML/CTF Compliance Officer
Every reporting entity needs a nominated Compliance Officer. This person is responsible for overseeing your AML/CTF Program and acting as the point of contact with AUSTRAC.
For solo practitioners, this will be you. For firms, it should be a senior partner or director with the authority to make compliance decisions.
Step 3: Draft your AML/CTF Program
Your AML/CTF Program is the foundation of everything. It needs to include:
- Part A: Customer identification and verification procedures
- Part B: Your approach to managing and mitigating ML/TF risk
AUSTRAC provides guidance on what to include, and tools like Next AML provide pre-built templates specifically designed for accounting practices.
Step 4: Set up your client due diligence process
Before the deadline, you should have a process in place for:
- Verifying new client identities (using reliable and independent documents or electronic verification)
- Identifying beneficial owners of companies and trusts
- Conducting risk assessments for each client engagement
- Documenting everything in an auditable format
Step 5: Choose your compliance tools
Trying to manage AML/CTF compliance with spreadsheets and filing cabinets is technically possible but practically unsustainable. Purpose-built software can automate reminders, structure your risk assessments, and keep you audit-ready at all times.
Next AML is built specifically for Australian accounting practices - designed to make compliance manageable without the overhead of enterprise software.
The bottom line: Start now, not in July. The firms that prepare early will find the transition much smoother than those who leave it to the last minute.