 Every AML session follows a familiar pattern. The presentation wraps up, the slides disappear, and then the real questions start. That is when the chat fills up with what people are actually concerned about. After running multiple AML discussions with hundreds of accounting professionals, the same themes kept surfacing for Seamlss. Most firms are not ignoring AML. They are simply unsure how to begin. When attendees were asked where they were at:
Below are the questions firms are asking most often, and the answers that matter. Do we need to verify all existing clients before July 2026? No. This is one of the biggest misunderstandings. Clients you already act for before 1 July 2026 are treated by AUSTRAC as pre commencement customers. That means customer due diligence is not automatically required. Verification is only triggered if:
If you have 200 clients on your books on 30 June 2026, you are not expected to verify 200 identities immediately. The requirement is to have systems in place so you can act when something changes. One important exception does apply. If you provide a new designated service to an existing client after 1 July 2026, due diligence must be completed before that service begins. Same client. New service. New obligation. We act as registered office for clients. Does this count? Yes. Registered office services are specifically listed as a designated service. Many firms do not think of this as a service because it is something they have always done. It may only come into play when ASIC correspondence arrives or details need to be updated. Even so, it is still captured under the reforms. If you were already providing this service before 1 July 2026, those arrangements fall under the pre commencement rules. There is no immediate requirement to verify clients unless something triggers action, such as:
Some firms are choosing to stop offering registered office services altogether. Others are keeping it and incorporating it into their AML program. Both approaches can be appropriate, but the key is making a deliberate decision rather than leaving things on autopilot. What if I am a director or shareholder in a client structure? This is also captured. Acting as a nominee director or shareholder is a designated service, even when it is done for estate planning or administrative reasons. This often affects accountants more than they expect. In these situations, the AML focus is on identifying and assessing the beneficial owners of the structure. In many cases, that is the same individuals you already advise. There is still some uncertainty about how these arrangements will work in practice. The good news is that existing arrangements are treated as pre commencement, which gives firms time to document them properly and include them in their AML framework. What about clients with foreign shareholders or payments we make for them? There are two separate considerations here. If you make payments on behalf of clients from accounts you manage or control, that activity is a designated service. Foreign ownership does not automatically make a client high risk. However, it is a factor in your risk assessment. Depending on the ownership structure and jurisdiction involved, it may increase the overall risk rating. For existing clients, the pre commencement rules still apply. Many firms are now thinking about whether their monitoring processes would actually identify unusual activity if it occurred. That is where the real work sits. Will clients feel uncomfortable being assessed as high risk? Some may, and that is not a reason to avoid it. AML compliance is becoming standard across professional services. Lawyers, real estate agents and financial advisers are all dealing with similar requirements. Most genuine clients understand that these checks are regulatory, not personal. Enhanced due diligence may involve:
If a client reacts poorly to reasonable compliance questions, that response is useful information in itself. If a client receives cash, do we need to report it? The ten thousand dollar threshold reporting obligation applies when you receive or pay physical cash. A client disclosing cash income for BAS or tax purposes does not automatically trigger a report. That said, patterns matter. If a client regularly receives large amounts of cash that do not align with their business profile or reported income, it is worth looking more closely. Cash heavy businesses are not inherently suspicious. Unexplained cash is. Why are financial planners not included? In many cases, they already are. Financial planners usually operate through product providers such as fund managers and platform operators. These organisations are already reporting entities and handle AML checks at the product level. The Tranche 2 reforms are aimed at professional services that were not previously covered, including accountants, lawyers, real estate agents and trust and company service providers. If a financial planner is also providing accounting services or establishing structures, those activities are treated the same way as any other firm’s. What firms should focus on now More detailed AUSTRAC guidance is expected in early this year, that will clarify many of the grey areas. For now, most firms do not need a lengthy AML manual. They need clarity on three core things: First, identify which designated services you actually provide. Many firms are doing more than they realise. Second, do not panic about existing clients. The pre commencement rules give you breathing room. Readiness is more important than speed. Third, plan how onboarding will change from 1 July 2026. Consider what information you will collect, how identity will be verified, and how the process will work in practice. Support is available Preparing for AML does not have to be a solo exercise. Many firms are working through the same questions and challenges, and having the right support can make the process far more manageable. Whether it is understanding which services are captured, planning changes to onboarding, or staying aligned with evolving guidance, help is available as firms move toward the July 2026 deadline. For firms using Seamlss, AML preparation is being built directly into the platform. AML is also being embedded into client onboarding, so compliance becomes part of day-to-day workflows rather than an extra administrative burden. A huge thanks to our friends at Seamlss for providing us with the insights needed for this article. Want to learn more? Don’t hesitate to reach out to us or directly to the team at Seamlss. Comments are closed.
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AuthorClarity Street was conceived from years of engaging with Accounting firms on a daily basis and a constant desire to make Accounting firms & SME’s more efficient and profitable. Archives
July 2026
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