Obligations are in effect·Enrolment deadline: 29 July 2026—21 days remaining
AML/CTF Compliance · Victorian Accountants · 5 min read · Klyvon Compliance Team
AML compliance for accountants in Victoria — AUSTRAC Tranche 2
Since 1 July 2026, Victorian accounting practices providing designated services must comply with AUSTRAC's AML/CTF requirements under the AML/CTF Amendment Act 2024. This guide explains exactly which accounting services trigger obligations in Victoria and across Australia, and how to comply now that obligations are in force — including the 29 July 2026 AUSTRAC enrolment deadline. For the full national accountants guide see /accountants.
Written by the Klyvon Compliance Team · Melbourne, Australia · General guidance only, not legal advice
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29 Jul 2026
AUSTRAC enrolment deadline
Nationwide including Victoria
AUSTRAC is a federal regulator — Victoria-wide obligations
AUSTRAC operates under Commonwealth law — the AML/CTF Act 2006 (Cth) — which applies Australia-wide. There is no Victorian-specific AML/CTF regime and no Victorian exemption. Accounting practices in Melbourne, Geelong, Ballarat, Bendigo, and regional Victoria are all subject to the same obligations as practices in Sydney, Brisbane, or Perth.
The Tranche 2 obligations are in addition to existing Victorian professional obligations under the Tax Practitioners Board, CPA Australia, Chartered Accountants Australia and New Zealand (CAANZ), and the Institute of Public Accountants (IPA). AML/CTF compliance is a separate federal regulatory layer.
Which accounting services are regulated in Victoria?
Designated (regulated)
✓ Forming companies or trusts for clients
✓ Acting as or arranging nominee directors or shareholders
✓ Managing or controlling client funds or assets
✓ Providing registered office services
✓ Acting in real property transactions
NOT regulated
✗ Tax return preparation and lodgement
✗ BAS and GST preparation
✗ Bookkeeping and payroll
✗ Financial statement preparation
✗ Management accounting
✗ Audit services
The three most common triggering services for Victorian accountants
SMSF and trust administration
Many Victorian accounting practices manage SMSF assets and administer discretionary trusts. Where the accountant exercises discretion over, or controls, client funds — rather than merely advising — this is a designated service. AUSTRAC has clarified that funds held solely as payment for your own services are exempt.
Company incorporations and business structuring
Forming a company or trust on behalf of a client, even once per year, is a designated service. The trigger is the nature of the service, not frequency. Many Victorian practices handle company incorporations as part of structuring advice — these practices are now reporting entities.
Nominee director or shareholder arrangements
Acting as, or arranging for a person to act as, a nominee director or shareholder is a designated service. This includes providing this service through a related company or entity.
Frequently asked questions
Do accountants in Victoria need to register with AUSTRAC?
Yes, if your Victorian accounting practice provides any designated accounting services under the AML/CTF Act 2006 as amended. AUSTRAC obligations apply Australia-wide — there is no Victoria-specific exemption. Designated accounting services include: forming companies or trusts for clients, acting as or arranging nominee directors or shareholders, managing or controlling client funds, and providing registered office services. General tax return preparation, BAS lodgement, and bookkeeping are not designated services.
What AML program does a Victorian accountant need?
Victorian accounting practices must implement an AML/CTF program covering a risk management framework — ML/TF risk assessment, compliance officer appointment, transaction monitoring, staff training, and audit — and customer due diligence — how you identify and verify client identity before providing a designated service. AUSTRAC no longer requires these to be structured as separate labelled 'Part A'/'Part B' sections since the 2024 reforms — organise the program as suits your practice. The program must reflect your practice's actual services and Victorian client base.
How much does AUSTRAC compliance cost for accountants in Victoria?
The government's Regulation Impact Statement estimated significant ongoing compliance costs for small businesses — covering staff time, external advice, and software. Klyvon is designed to reduce that cost substantially. Boutique AML consultants charge $5,000–$15,000 for accounting firm programs. Klyvon is purpose-built for Australian accountants including Victorian practices — it generates a firm-specific AML/CTF program in one session from $299/month.
What happens if a Victorian accountant doesn't comply now obligations are in force?
Operating as a reporting entity without an AML/CTF program and CDD procedures is a contravention of the AML/CTF Act 2006 — obligations have applied since 1 July 2026. Civil penalties can reach $33,000,000 per contravention for bodies corporate (based on the current penalty unit rate of $330; due to re-index 1 July 2026 pending official publication). Non-enrolment after 29 July 2026 attracts daily penalties of up to $19,800. AUSTRAC publishes all enforcement actions publicly, creating reputational consequences beyond financial penalties.
Can Victorian accountants use AI to generate their AML program?
Yes. Klyvon is purpose-built for Australian accountants including those in Victoria — it generates a firm-specific AML/CTF program in one session from $299/month. The AI is prompted with AUSTRAC's published Accountants Starter Kit and sector guidance as context. The generated program covers your risk framework and CDD procedures specific to accounting practices including company formation and trust arrangements. The program must be reviewed and adopted by your compliance officer before implementation.
How often must a Victorian accounting practice get an independent evaluation of its AML/CTF program?
At least once every 3 years, and more often if appropriate to the size and complexity of your practice. This is a separate, mandatory requirement under the AML/CTF Act — distinct from your annual internal program review. The independent evaluation must assess your ML/TF risk assessment, the design of your AML/CTF policies, your actual compliance with those policies, and whether you're appropriately identifying, assessing, and mitigating ML/TF risk. Applies to Victorian practices the same as anywhere else in Australia — AUSTRAC is a federal regulator.
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General guidance only · Not legal advice · austrac.gov.au