From 1 July 2026, Australia’s Anti‑Money Laundering and Counter‑Terrorism Financing (AML/CTF) regime will expand to include accountants and other professional advisers under what is known as “Tranche 2”. This is a major regulatory reform aimed at strengthening Australia’s ability to detect, prevent, and disrupt financial crime.
While not all services provided by HFB will fall under this new regime, several ‘designated services’ commonly offered by accounting firms will be captured. As your trusted advisers, we want to ensure you understand what is changing, how it affects our work together, and what you can expect from us going forward.
Why these changes are being introduced
The Federal Government is expanding the AML/CTF Act to cover professionals who help facilitate high‑value transactions or create business and financial structures. These professions include accountants, lawyers, and real estate agents.
The introduction of Tranche 2 aims to bring Australia in line with international practices recommended by the Financial Action Task Force (FATF).
Which HFB services will now be regulated?
Only specific services are captured under the Tranche 2 reforms, and they include situations where an accountant assists in setting up or managing financial structures, facilitating transactions, or acting on behalf of a client. AUSTRAC identifies these services as higher‑risk because they can be misused to hide beneficial ownership or move illicit funds.
At HFB, the designated services include:
- Acting as a registered office for your company
- Setting up companies, trusts, or self‑managed super funds (SMSFs)
- Assisting with business purchases or sales, including due diligence
- Helping with entity restructures or changes to ownership structures
Routine accounting and tax services are typically not captured.
What this means for you as a client
These new rules do not change the services we offer, but they will change some of the processes we must follow when providing them, in particular:
- Additional identification and verification requirements
- Whenever you request a designated service, we will need to complete ‘customer due diligence’ (CDD), which may include:
- Verifying your identity and beneficial ownership
- Confirming the purpose and nature of the service requested
- Enhanced checks for higher‑risk situations (e.g., complex structures, overseas connections)
- Whenever you request a designated service, we will need to complete ‘customer due diligence’ (CDD), which may include:
- Ongoing information updates
- We will periodically ask you to confirm or update:
- Contact details
- Ownership information
- Source of funds or source of wealth (where relevant)
- Details relating to the activity we are assisting with
- This means more questions from us — but these checks are mandated and designed to protect both you and the wider financial system.
- We will periodically ask you to confirm or update:
- Record‑keeping and reporting obligations
- For designated services, we may be required to:
- Keep records of identification and verification
- Retain documents relating to your transactions and structures
- Report suspicious matters to AUSTRAC, where necessary
- For designated services, we may be required to:
How this protects you
Although these reforms introduce extra steps, they also provide significant benefits for clients:
- Reduced risk of your structures being misused by third parties
- Stronger safeguards against identity fraud and unauthorised transactions
- Greater integrity in Australia’s financial and business environment
These protections can help reassure lenders, investors, regulators, and other stakeholders who rely on transparent, well‑governed financial arrangements.
What you can expect from HFB
HFB is fully committed to complying with the new AML/CTF regime in a way that is practical, efficient, and respectful of your time.
Before 1 July 2026, we will be finalising our AML/CTF program and introducing updated client onboarding and verification tools. We want to ensure our processes are as streamlined as possible, with our goal to provide a smooth, client-friendly experience – while also meeting the new regulatory standards.