What Is AML/CTF? What Accumen Clients Need to Know


Compliance Update

AML/CTF Changes 2026: What Every Accumen Client Needs to Know

From 1 July 2026, new federal laws require us to verify your identity before providing certain services. Here’s exactly what’s changing, what it means for you, and, importantly, why existing clients don’t need to do anything right now.


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On 1 July 2026, the Anti-Money Laundering and Counter-Terrorism Financing Act extended what are known as ‘Tranche 2’ obligations to accounting firms across Australia. These reforms bring Australian accounting practices into line with international standards set by the Financial Action Task Force (FATF) – making Australia one of the last OECD countries to take this step.

Here’s what it means for you and your business relationship with Accumen.

Why Is This Happening?

Money laundering and financial crime frequently exploit professional services – accountants, lawyers, and real estate agents are commonly used to move and conceal criminal proceeds. The Tranche 2 reforms close that gap, extending Know Your Client (KYC) obligations to accounting and advisory firms. AUSTRAC, Australia’s financial intelligence agency, is overseeing implementation.

Which Services Are Affected?

Not all accounting work is caught. The obligations apply specifically to ‘designated services’ – those involving legal structures or significant financial transactions:

  • Setting up or dissolving companies, trusts, SMSFs, or partnerships
  • Providing or arranging a registered office or business address
  • Acting as (or arranging) a nominee director or shareholder
  • Assisting with property transactions
  • Assisting with business acquisitions, sales, or restructures

✅  Your annual tax return, BAS preparation, and general accounting advice are NOT designated services. Those continue exactly as they do now – no interruption, no new requirements.

If You’re an Existing Client – What ‘Pre-Commencement’ Means

🛡️  No immediate action required for existing clients

If you were already a client of Accumen before 1 July 2026, you are classified as a ‘pre-commencement client’ under the legislation. This means we are not required to verify your identity on 1 July. The verification requirement applies the next time you request a designated service – not before.

In practical terms: if you come to us in August to set up a new family trust, or in October to restructure your company, that is when we will ask for identity documents – before we begin that specific piece of work. Your regular tax and accounting work is completely unaffected.

If You’re a New Client

If you are engaging Accumen for the first time after 1 July 2026, identity verification is required before we can commence any designated service. We will provide you with a personalised checklist of exactly what’s needed – the process typically takes a matter of days.

What the Verification Process Looks Like

When the time comes, we’ll ask for identity documents suited to your situation:

🪪  Individuals – current passport or driver’s licence

🏢  Companies – ASIC extract plus ID for each director and beneficial owner

📄  Trusts – certified copy of the trust deed plus trustee and beneficiary IDs

🏦  SMSFs – trust deed, ATO registration confirmation, and member IDs

🤝  Partnerships – partnership agreement plus partner IDs

We’ll provide a personalised checklist for you to complete. Most clients are through the process within a few days.

What Happens to Your Information?

Your documents are handled with strict confidentiality. They are stored securely, used only for identity verification purposes, and retained for the minimum period required by law. We do not sell or misuse your personal information.

What Should You Do Right Now?

If you are an existing client – nothing. We will contact you when a designated service triggers the requirement. If you have a transaction on the horizon (a new entity, a property purchase, a restructure), simply be aware the verification step is coming so it doesn’t delay your timeline.

If you have questions, please get in touch. We are committed to making this as straightforward as possible.

Frequently Asked Questions

The questions we hear most from clients about the new AML/CTF requirements.

+  Why are you asking for my passport and driver’s licence?

Under the new AML/CTF laws, we are legally required to verify the identity of every client before providing certain services. Government-issued photo ID – your passport or driver’s licence – is the most straightforward way to do that, because it confirms both your identity and your face.

We understand handing over these documents can feel unfamiliar in an accounting context. But this is now a standard requirement across accounting, legal, and financial services – the same requirement you’d encounter at a bank or conveyancer. We treat your documents with the same strict confidentiality as everything else you share with us.

+  Why is Accumen asking for my identity documents now, when we’ve been working together for years?

New federal legislation – the AML/CTF Act – requires us to formally verify client identities before providing certain designated services. Because you are an existing client, we were not required to do this on 1 July 2026. The requirement applies now because you have requested a service that triggers it. We are not singling you out – this applies to all clients when they request this type of work.

+  Does this mean Accumen suspects me of something?

Absolutely not. Identity verification is required for every client without exception, regardless of history or relationship. It is simply the law, and it applies uniformly across our entire client base – exactly as it does at banks, conveyancers, and financial planners.

+  What services trigger these checks?

The checks apply when Accumen assists with forming or restructuring companies, trusts, SMSFs or partnerships; providing a registered office address; assisting with property transactions; assisting with business acquisitions or restructures; or acting as a nominee director or shareholder.

Tax returns, BAS preparation and general accounting advice are not affected.

+  Will I need to do this every time I engage Accumen?

No. Once your identity has been verified, the information stays on file. You won’t need to repeat the process unless your circumstances change significantly – for example, changes to ownership structure, new entities, or a significant change in the nature of your engagement with us.

+  What documents do I need to provide?

It depends on your structure. In general:

🪪  Individuals – current passport or driver’s licence

🏢  Companies – ASIC extract plus ID for each director and beneficial owner

📄  Trusts – certified copy of the trust deed plus trustee and beneficiary IDs

🏦  SMSFs – trust deed, ATO registration confirmation, and member IDs

🤝  Partnerships – partnership agreement plus partner IDs

We’ll send you a personalised checklist when the time comes.

+  Is my information kept confidential?

Yes. Your privacy is protected at every step. Accumen is not permitted to retain copies of your identity documents – we sight them through InfoTrackID’s secure platform for verification purposes only. We do retain a record of the verification (date, method, and outcome) for 7 years as required by the AML/CTF Act, but your actual documents are never held by us.

We do not share your information with third parties except as required by law.

+  What if I can’t provide all the documents?

Please contact us as soon as possible. We cannot begin work until verification is complete, so resolving any gaps promptly avoids delays to your matter. Alternative documents may be acceptable in some circumstances – just ask us.

+  What happens if Accumen reports something to AUSTRAC?

We are required to report certain transactions and suspicious matters to AUSTRAC. If we make such a report, we are legally prohibited from informing you – this is called the ‘tipping-off’ rule under the AML/CTF Act. This is standard across all accounting and financial services in Australia, not unique to Accumen.

+  Who is InfoTrack and why is Accumen using them?

InfoTrack is one of Australia’s leading legal and professional services technology platforms, used daily by thousands of law firms, conveyancers, and accounting practices across the country. They have been operating in the Australian professional services sector for over 20 years and are widely regarded as the industry standard for identity verification and due diligence.

We use InfoTrack’s identity verification product – InfoTrackID – because it allows identity documents to be verified securely without Accumen ever handling or storing copies of those documents. This protects your privacy while satisfying our legal obligations under the AML/CTF Act. InfoTrackID verifies documents against the Australian Government’s Document Verification Service (DVS), making the check authoritative and government-backed.

+  What does InfoTrack do with the identity documents I provide?

When you complete the InfoTrackID verification process, your documents are checked against the Australian Government’s Document Verification Service (DVS) within InfoTrack’s secure system. The documents are used solely to confirm your identity – nothing else.

InfoTrack retains your identity documents and personal information within their secure platform for 90 days only, after which everything is permanently and irreversibly deleted. They do not sell, share, or use your information for any other purpose.

Accumen receives only the outcome of the verification – a record confirming that your identity was verified, when, and by what method. We never receive copies of your documents. That record is retained by Accumen for 7 years as required by the AML/CTF Act, but your actual documents are never in our possession at any point.

+  Is the InfoTrackID process safe? Can I trust it?

Yes. InfoTrack operates enterprise-grade security infrastructure with onshore data storage – meaning your information never leaves Australia. Their platform is compliant with the Privacy Act 1988 and the Australian Privacy Principles, and it is independently audited.

InfoTrackID is the same platform used by thousands of Australian law firms and conveyancers to verify client identities for property transactions. It is well-established, widely trusted, and purpose-built for exactly this type of sensitive verification work. You can review their security legislation compliance at any time.

+  Does Accumen keep copies of my identity documents?

No – and we are not permitted to. Under our privacy obligations, Accumen sights your identity documents through the InfoTrackID platform but does not retain copies. The only thing we record and retain is the verification outcome – the date verification was completed, the method used, and the result. Your actual documents remain within InfoTrack’s secure system and are permanently deleted after 90 days.

+  Can I complete the verification in person instead of online?

Yes. InfoTrackID supports both remote verification (online, at a time that suits you) and in-person verification at our Bathurst office. If you would prefer to complete the process face-to-face, please let us know and we will arrange that with you. Either way, the same privacy protections apply – Accumen does not retain copies of your documents regardless of how the verification is conducted.

+  My trust was set up 20 years ago and I can’t find the trust deed – what do I do?

This is more common than you might think, and it’s worth sorting out now rather than when you need us to act on the trust. We cannot complete identity verification for a trust without sighting the trust deed – it is required to confirm the trust structure, trustee powers, and beneficial ownership.

If your deed is missing, start by checking with the solicitor or accountant who set up the trust – they may have a copy. If it was set up through a document provider, a replacement certified copy may be obtainable. In some cases legal advice may be required. Please contact us as early as possible so we have time to resolve it before it delays a transaction.

Have questions?

We’re here to help.

Reach out to the Accumen team to discuss how the new AML requirements apply to your situation.

Contact Us →

02 6338 2388  ·  admin@accumen.com.au  ·  accumen.com.au

Further information: This article has been prepared for general information purposes based on AUSTRAC’s published guidance, including the Accounting Program Starter Kit and AML/CTF Act 2024. It is not legal advice. For general public information on identity verification requirements, visit austrac.gov.au. Accumen recommends seeking independent legal advice for specific compliance questions.