Obligations are in effect·Enrolment deadline: 29 July 2026—10 days remaining
Sector Guide · Victorian Accountants
Same federal law. No Victorian exemption.
- $36.4M
- Max civil penalty
- 29 Jul
- Enrolment deadline
- 3 yrs
- Independent evaluation
- $299/mo
- Klyvon for accountants
I. The Jurisdiction Question
AUSTRAC doesn't care which state you practise in
very year, a handful of Victorian practices ask the same question a different way — does being based in Melbourne, Geelong, or regional Victoria change anything? It doesn’t. The AML/CTF Act 2006 is Commonwealth law, and it runs the same obligations, the same deadlines, and the same penalties over a firm in Ballarat as it does over one in Sydney or Perth. There is no Victorian carve-out, no state-based grace period, and no local regulator standing between your practice and AUSTRAC.
What Victorian practices do carry is an extra layer, not a substitute one. Your existing obligations to the Tax Practitioners Board, CPA Australia, Chartered Accountants Australia and New Zealand, or the Institute of Public Accountants haven’t gone anywhere — AML/CTF compliance sits alongside them as a separate federal requirement, triggered by what you do for clients rather than by where your office happens to be.
“There is no Victorian-specific AML/CTF regime and no Victorian exemption.”
— AML/CTF Act 2006 (Cth)
II. Where the Line Sits
Most of what accounting practices do is untouched
Tax, BAS, bookkeeping, audit — the bread-and-butter work of a Victorian practice sits entirely outside AUSTRAC's reach. The obligation only switches on for a specific, narrow band of services.
Designated
A reporting entity under the Act
- 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 designated
Outside AUSTRAC’s scope
- Tax return preparation and lodgement
- BAS and GST preparation
- Bookkeeping and payroll
- Financial statement preparation
- Management accounting
- Audit services
The trigger is the nature of the service, not how often you provide it or how large your practice is.
III. Where Victorian Practices Actually Trip This
Three services catch more firms than any others
These aren't edge cases — they're the ordinary, everyday work a lot of Victorian practices already do without realising it crosses into designated territory.
SMSF and trust administration
Plenty of Victorian practices manage SMSF assets or administer a client's discretionary trust without ever thinking of themselves as a reporting entity. The line that matters is discretion. If you're advising on a fund, you're outside scope. The moment you exercise discretion over — or control — a client's funds rather than simply advising on them, that service is designated. Funds held solely as payment for your own fees are carved out.
Company incorporations and structuring
It doesn't take volume to trigger this one. Forming a company or trust for a client, even a single time in a year, is enough. A lot of Melbourne and regional Victorian practices fold incorporations into broader structuring advice without separating it out — but AUSTRAC looks at the nature of the service, not how often you provide it. If you've formed even one entity for a client, you're a reporting entity from that day.
Nominee director or shareholder arrangements
Acting as a nominee director or shareholder — or arranging for someone else to, including through a related entity — is designated in its own right. Firms sometimes route this through an associated corporate services arm and assume it sits outside the accounting practice's obligations. It doesn't. The obligation follows the service, wherever in your structure it's performed.
IV. What the Program Has to Cover
One document, two jobs
Since the 2024 reforms, AUSTRAC no longer insists on separately labelled 'Part A' and 'Part B' sections — but every program still has to do both jobs: assess your risk, and verify who you're dealing with.
For a Victorian practice that forms entities or administers trusts, customer due diligence tends to be where the real work is — not because the risk framework is trivial, but because CDD has to happen client-by-client, before the designated service starts. Four checks come up more than any others:
Verify the entity
Confirm the client's legal structure — company, trust, partnership — before you form or manage anything on their behalf.
Identify beneficial owners
Trace through to the individuals who actually own or control the entity, not just the named directors.
Screen for PEPs
Check whether the client or a beneficial owner is a politically exposed person before the designated service begins.
Understand the funds
Know where the money in a trust or nominee arrangement is coming from before you agree to control or manage it.
V. Reference
Everything else Victorian practices ask
VI. How Klyvon Helps
Generate your Victorian accounting practice’s AML/CTF program in one session
Built for accountants
Prompted with AUSTRAC's published Accountants Starter Kit and sector guidance — covering trust and nominee arrangements specific to accounting practices.
Reviewed by your CO
The generated program is a starting point for review by your compliance officer before adoption. All decisions remain with your firm.
Built on current law
Every program cites the AML/CTF Act 2006 and current AUSTRAC guidance — no Victoria-specific gaps, no generic template.
Answers instead of pointing you at a PDF
No other Tranche 2 platform in Australia does this.
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General guidance only · Not legal advice · austrac.gov.au