What the bodies have done
CPA Australia, Chartered Accountants ANZ and the Institute of Public Accountants engaged with the Tranche 2 consultation and have published member guidance on designated services, enrolment and programs. The Institute of Certified Bookkeepers has done the same for bookkeepers and BAS agents, with a focus on when a bookkeeper is and is not caught. Check each body's website for the current material; it is updated as AUSTRAC releases rules and guidance.
Conduct obligations
Failing to comply with the law of the profession can be a conduct matter under each body's by-laws. Practically, a member found to be providing designated services with no program and no client identification should expect the body to take an interest.
CPD
AML/CTF training you run for your own staff can usually be counted towards continuing professional development. Keep the record; it serves both purposes.
Use the guidance, keep your own records
Body guidance explains the law; it is not your program. Your program must describe your firm. Templates from the bodies are a fine starting point if you then tailor and adopt them.
Questions people ask
- Does my body's practising certificate cover AML?
- No. AUSTRAC enrolment is separate and required regardless of your practising certificate.
- Will the body audit my AML compliance?
- Quality reviews may ask whether you have a program and client identification in place. AUSTRAC is the regulator; the bodies are interested in conduct.
This guide is general information for accountants, bookkeepers, BAS agents, not legal advice. Check AUSTRAC's current guidance for your situation.