The Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006 recently underwent significant reforms. As a result, from 1 July 2026, accounting firms such as illumin8 that provide certain designated services will become regulated by AUSTRAC, Australia's AML/CTF regulator. AUSTRAC's role is to detect, deter and disrupt money laundering, terrorism financing, and serious and organised crime. While the AML/CTF Act itself is not new, the reforms expand the regime to include accountants, lawyers, real estate professionals and other service providers that perform certain higher-risk activities. Where an accounting firm provides a designated service, it becomes a ‘reporting entity’ under the legislation and must comply with a range of AML/CTF obligations. Most people have already encountered AML/CTF requirements in everyday life, including:
- Banks conducting identity verification checks when opening accounts.
- Providing proof of income, assets, or source of funds when applying for loans or making significant purchases.
- Declaring cash amounts exceeding $10,000 when crossing international borders.
- Financial institutions monitoring transactions for unusual activity.
What Does This Mean for illumin8?
As a reporting entity, illumin8 must implement and maintain an AML/CTF compliance program that includes:
- Customer identification and verification procedures.
- Risk assessments for clients and services provided.
- Ongoing monitoring of certain client relationships.
- Record-keeping requirements.
- Reporting obligations to AUSTRAC where required.
- A documented risk appetite framework that helps determine when we can onboard, continue servicing, or, in some cases, offboard a client under our AML/CTF obligations.
This means that when we provide certain designated services, we are required to collect additional information and complete specific verification processes before we can proceed.
What Does This Mean for Clients?
For most clients, the impact will be minimal and largely administrative.The new requirements generally affect:
- New clients engaging us for designated services.
- Existing clients who request services that fall within the designated service categories.
- Client groups where one entity triggers AML/CTF obligations and related entities within the group may also need to be assessed.
In most cases, the process will be straightforward. However, we may be unable to commence or continue certain work until the required information has been received and verified.
Information We May Request
Clients may be asked to:
- Complete a client identification form.
- Provide proof of identity documents (such as a passport or driver's licence).
- Consent to electronic identity verification.
- Undergo sanctions screening.
- Undergo Politically Exposed Person (PEP) screening.
- Undergo adverse media screening.
- Provide trust deeds, company constitutions, and other establishment documents.
- Provide details of any individual who directly or indirectly owns or controls 25% or more of a company, trust, or other legal arrangement.
- Provide information regarding the source of funds or source of wealth where appropriate.
We are also required to conduct verification and monitoring of non-individual entities, including companies, trusts, self-managed superannuation funds (SMSFs), and other legal structures for as long as designated services are being provided.
What Will Trigger AML/CTF Requirements?
There are nine designated services applicable to the accounting profession under the Tranche 2 reforms.
Services Relevant to illumin8
The following designated services may be provided by illumin8 and may trigger AML/CTF obligations:
1. Assisting in the planning or execution of the sale, purchase or transfer of a company or legal arrangement (Item 2)
Examples include:
- Business acquisitions or disposals.
- Company share transfers.
- Trust ownership changes.
2. Assisting in the creation or restructuring of a company or legal arrangement (Item 6)
Examples include:
- Company formations.
- Trust establishments.
- Changes to shareholdings.
- Appointment or removal of directors and officeholders.
- Corporate restructures and ownership changes lodged with ASIC.
3. Providing a registered office address or principal place of business address (Item 9)
This generally applies where illumin8 provides a registered office address or principal place of business address for a company.
Services Not Typically Provided by illumin8
The following designated services exist under the legislation but are generally not provided by illumin8:
- Assisting with real estate transactions (Item 1).
- Receiving, holding, controlling or managing client funds or property for transactions (Item 3).
- Assisting with equity or debt financing transactions (Item 4).
- Selling or transferring shelf companies (Item 5).
- Acting as, or arranging, directors, trustees, company secretaries or nominee shareholders (Items 7–8).
Important Note for Client Groups
Where one entity within a client group triggers AML/CTF requirements, related entities may also need to undergo verification.
For example, if a company within a group engages illumin8 to provide a designated service such as a shareholding restructure, company acquisition, or registered office service, we may also need to obtain information relating to associated companies, trusts, SMSFs, and beneficial owners within that group structure.
What Clients Can Expect
For most legitimate clients, the primary impact of the reforms will be:
- Additional identity verification requirements.
- Requests for ownership and control information.
- Additional documentation for trusts, companies and SMSFs.
- Potentially longer onboarding or transaction timeframes.
- Ongoing monitoring where designated services continue to be provided.
These measures are designed to protect Australia's financial system and help prevent money laundering, terrorism financing, fraud, and other serious criminal activity.We appreciate your cooperation as we implement these new regulatory requirements and will work to make the process as seamless as possible.
