Obligations commence: 1 July 2026·Enrolment deadline: 29 July 2026—27 days remaining
AML/CTF Compliance · Victorian Accountants
AML compliance for accountants in Victoria — AUSTRAC Tranche 2
From 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 before the 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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1 Jul 2026
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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
Source: AML/CTF Act 2006, s.6(5B) Table 6.
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 under Table 6. The trigger is the nature of the service, not frequency. Many Victorian practices handle company incorporations as part of structuring advice — these practices are 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 Table 6 of s.6(5B) of 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 with two mandatory parts. Part A covers your practice's risk management framework — ML/TF risk assessment, compliance officer appointment, transaction monitoring, staff training, and audit. Part B covers customer due diligence — how you identify and verify client identity before providing a designated service. The program must reflect your practice's actual services and Victorian client base.
How much does AUSTRAC compliance cost for accountants in Victoria?
The Australian Government's Regulatory Impact Statement estimated $23,250 average one-time preparation cost using external consultants. 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 60 seconds from $79/month, with a 7-day free trial.
What happens if a Victorian accountant doesn't comply by July 2026?
Operating as a reporting entity without an AML/CTF program and CDD procedures from 1 July 2026 is a contravention of the AML/CTF Act 2006. Civil penalties can reach $33,000,000 per contravention for bodies corporate. Non-enrolment after 29 July 2026 attracts daily penalties of up to $18,780. 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 60 seconds from $79/month. The AI is trained on AUSTRAC's published Accountants Starter Kit and sector guidance. The generated program covers Part A (risk framework) and Part B (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.
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Klyvon generates your complete AML/CTF program in 60 seconds. From $79/month — 7-day free trial.
General guidance only · Not legal advice · Source: AML/CTF Act 2006, s.6(5B) · austrac.gov.au