From 1 July 2026, Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime will expand to include professions such as accountants, lawyers and real estate agents.
While these changes are regulatory in nature, the most visible impact for clients will be an increase in ‘Know Your Customer’ (KYC) and identity verification requirements for the engaged service provider, resulting in additional questions, document requests and verification steps.
This article outlines what you are likely to be asked, when it will happen, and how to prepare.
When Will You Be Asked for Information?
You will only be subject to these checks when your professional service provider is supplying a ‘designated service’ — typically where there is movement of funds, changes in ownership, or structuring involved.
Common situations where you should expect additional scrutiny include:
- Buying or selling property
- Setting up or restructuring companies or trusts
- Entering into complex financial or investment arrangements
- Transactions involving large sums of money
- Where your professional service provider is handling or directing funds on your behalf
Routine advisory work (e.g. tax compliance or general advice) is less likely to trigger formal checks unless it connects to one of the above activities.
What Questions Will You Be Asked?
Depending on the nature of the engagement, expect questions in three broad areas:
1. Identity and Verification
To confirm you are who you say you are, you may be asked to provide:
- Passport or driver’s licence
- Residential address details
- Date of birth
For businesses or entities:
- Decide your margin strategy: move costs into headline prices (across-the-board) or apply targeted price adjustments to products/services where card usage is highest.
- Update all customer-facing references to surcharges (menus, signage, websites, FAQs, T&Cs, invoices, quotes), so nothing conflicts with the post‑ 1 October settings.
2. Ownership and Control (Beneficial Ownership)
If you operate through a company, trust or other structure, professional service advisers will need to understand who ultimately owns or controls it.
You may be asked:
- Who are the ultimate shareholders or beneficiaries?
- Does anyone exercise control through voting rights or influence?
- Are there layers of entities involved (e.g. holding companies, family trusts)?
This is often the area clients find most detailed, particularly in complex structures.
3. Purpose of the Transaction
Professional service advisers are required to understand why a transaction is taking place.
Expect questions such as:
- What is the commercial purpose of the transaction?
- Where are the funds coming from (e.g. savings, loan, asset sale)?
- Is this a one-off transaction or part of a broader strategy?
These questions are not about judgement, they are about documenting the rationale and ensuring it is consistent with the overall engagement.
What Should You Prepare in Advance?
To make the process smooth, it is worth having the following readily available:
For Individuals:
- Valid photo ID
- Proof of address (if required)
- Basic understanding of your funding sources
For Businesses or Trusts:
- Current ASIC extract or trust deed
- Ownership structure diagram (if available)
- Details of all key stakeholders / beneficiaries
- Identification documents for controlling individuals
For Transactions:
- A clear explanation of:
- What you are doing
- Why you are doing it
- Where funds are coming from
Being prepared upfront will significantly reduce delays once these reforms commence.
What Will Feel Different?
From a client perspective, the main changes compared to today are:
- More upfront information requests, even for long-standing relationships
- More structured questioning, particularly around ownership and purpose
- Less flexibility to proceed without documentation, even where the professional service adviser “knows” the client
In other words, processes will become more formalised and consistent, rather than discretionary.
Although it may feel administrative, these changes are designed to:
- Protect the integrity of transactions
- Reduce risk of fraud, misuse of structures or identity
- Ensure Australia remains aligned with international regulatory standards
For clients, this ultimately supports a more secure and trusted business environment, particularly in high-value or complex dealings.
Conclusion
If you are planning a transaction or structural change in the next 12–24 months, it is worth factoring in additional onboarding and verification steps as part of your timeline.
Your professional service adviser will guide you through what is required – but being prepared will ensure the process is efficient and friction-free.
Do you need help?
If you would like to discuss the new AML/CTF regime or need help with preparing any of the documentation, please reach out to our team through the contact form, or by calling us at 02 8226 1655.
Further information can also be found on the AUSTRAC website by the Australian Government.
Important Information – General Advice Disclaimer:
The information provided in this communication is general in nature and does not take into account your personal objectives, financial situation, or needs. Before acting on any information, you should consider its appropriateness in relation to your own circumstances and seek independent financial advice where necessary. We recommend consulting a licensed financial adviser before making any investment or financial decisions. Past performance is not a reliable indicator of future performance.
