AML Hub - Compliant Registrations

Company & Trust Registrations - AML/CTF Ready

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AML Compliance Hub

Australia’s Anti Money Laundering and Counter Terrorism Financing laws are designed to protect the financial system by preventing criminal proceeds from being legitimised and restricting the flow of funds to terrorist organisations. Traditionally, these obligations applied primarily to banks, financial institutions, and remittance providers. Recent reforms passed by Parliament have significantly expanded the scope of the regime to include a broader range of professional services, including the accounting, legal, and corporate advisory sectors in which many Abbots clients operate.

What is AML/CTF Compliance?

AML/CTF compliance refers to the regulatory obligations imposed on certain businesses and professional service providers to help safeguard Australia’s financial system from criminal misuse. These obligations require organisations to undertake appropriate customer identification and verification procedures, understand the nature and purpose of client relationships, monitor transactions and activities for unusual or suspicious behaviour, and report certain matters to Australia’s financial intelligence agency, AUSTRAC. The framework is designed to strengthen transparency and accountability across industries that may be exposed to financial crime risks. For accounting, legal, and corporate advisory practices, this means implementing processes that support ongoing client due diligence, risk assessment, record keeping, and internal compliance controls.

Know your Customer - Businesses must take reasonable steps to verify the identity of the individuals and entities they are dealing with before providing designated services. This includes identifying beneficial owners and understanding the real individuals behind companies, trusts, partnerships, and other corporate structures to ensure transparency and reduce the risk of financial exposure.
Monitor Transactions – Ongoing monitoring procedures are required to ensure client transactions and activities remain consistent with the nature of the engagement, the client’s known business activities, and expected source of funds. Businesses should be able to identify and assess activity that appears unusual, inconsistent, or potentially suspicious.
Report to AUSTRAC – Where required under the AML/CTF legislation, businesses must lodge reports with AUSTRAC, including Suspicious Matter Reports and Threshold Transaction Reports, as part of their ongoing compliance obligations. Reporting entities are also required to maintain accurate enrolment details, comply with annual reporting requirements, and ensure records are retained in accordance with legislative timeframes. AUSTRAC has broad regulatory and enforcement powers, including the ability to conduct compliance reviews and audits of accounting, legal, and professional service firms to assess whether appropriate AML/CTF systems, controls, and procedures have been implemented and maintained.
Maintain a Program – Businesses must establish and maintain a documented AML/CTF compliance program that outlines their internal policies, procedures, controls, and risk management framework. Organisations are also required to retain relevant records for a minimum of seven years and ensure staff receive ongoing training to understand their compliance responsibilities and identify potential risks in practice.

Keep up to date: Deadlines are set by AUSTRAC and may change. Always refer to austrac.gov.au for current dates, or contact the Abbots team.

Our AML-Ready Registrations

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Our registrations and their AML/CTF compliance benefit

Each Abbots product directly supports one or more of your AML/CTF obligations.

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Company Registration

Company registrations completed through Abbots include a comprehensive suite of ASIC compliant establishment documents designed to support accountants and advisers from the outset. Each company package includes a current constitution, member and officeholder registers, share certificates, and related corporate records, providing a clear and properly constituted documentary foundation that can assist firms with their client onboarding, record keeping, and broader AML/CTF verification processes.

✓ ASIC Compliant ✓ ASIC Digital Service Provider ✓ Compliant Constutiton

Discretionary Trust

Discretionary trust deeds issued through Abbots are carefully drafted to clearly set out the structure of the trust, including the settlor, trustee, appointor, and defined classes of potential beneficiaries. This level of clarity is intended to assist accountants in understanding the intended scope of the trust relationship, supporting more efficient administration and providing greater ease when undertaking client onboarding and AML/CTF related verification processes.

✓ Registered with Victoria & NSW Revenue Office ✓ Trust Registration Australia Wide ✓ Curent Trust Deeds

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Self-Managed Super Fund

SSMSF compliance expectations have continued to increase, with many funds now operating with up to six members and a broader range of investment strategies across individuals. In this environment, it is important to have a governing deed that is sufficiently flexible to accommodate the differing needs and arrangements of multiple members while still maintaining clear structure and governance. SMSF documents prepared through Abbots are drafted to support this flexibility, helping accountants manage ongoing administration more efficiently and providing clearer documentation that can assist auditors in their review and compliance processes.

✓ Current Governing Deed ✓ SMSF Registration Australia Wide ✓ SMSF Bank Kits

Core compliance obligations

Once your business is identified as a reporting entity, you must build and maintain an AML/CTF compliance program. Click each obligation to expand.

All reporting entities must enrol with AUSTRAC before providing designated services. Enrolment is done online and must be completed before compliance deadlines take effect. Check austrac.gov.au for current enrolment timeframes.
A written program documenting your risk assessment, policies, procedures, and controls for identifying and managing money laundering and terrorism financing risks. The program must be reviewed regularly and kept up to date.
Before providing services, you must collect and verify information about who your client is — including verifying the identity of individuals and, for corporate clients, identifying the beneficial owners who ultimately own or control the entity.
Your obligations do not end at onboarding. You must continue to monitor clients and their transactions throughout the relationship, and apply enhanced scrutiny to higher-risk clients including Politically Exposed Persons (PEPs).
If you have reasonable grounds to suspect that a transaction or client is connected to criminal activity, you must file a Suspicious Matter Report with AUSTRAC as soon as practicable — generally within 24 hours for transactions, or three business days otherwise.
Cash transactions of $10,000 or more (or foreign currency equivalent) must be reported to AUSTRAC within ten business days, regardless of whether the transaction appears suspicious.
All records relating to customer identification, transactions, and AML/CTF program documentation must be retained for a minimum of seven years. Records must be stored in a way that makes them retrievable for AUSTRAC if requested.
Employees involved in providing designated services must be trained on the AML/CTF program, their obligations, and how to identify suspicious activity. Training must be ongoing and documented.

How do the company and trust documents I register through Abbots support my AML/CTF obligations?

Reporting entities must verify the identity of clients and identify the beneficial owners of every entity they deal with before providing a designated service. To complete this process accurately, you need a current, correctly executed constitution, trust deed, or governing document, together with accurate registers of members and officeholders.

As a professional services entity am I a reporting entity under Australia's AML/CTF laws?

Generally speaking, yes. Under section 5 of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (the AML/CTF Act), a "reporting entity" is any person or business that provides a "designated service" listed in section 6 of the Act. The designated services most relevant to accountants include forming, operating, or managing a company, partnership, or trust on behalf of a client; preparing or lodging documents with a government body on behalf of a client; and managing client funds. This means that if you register companies or establish trusts on behalf of clients as part of your practice, you maybe reporting entity. AUSTRAC operates an online checker at austrac.gov.au to help you confirm whether your specific services are captured. If you are uncertain, seek independent legal advice.

What is beneficial ownership and how do I identify it for a company or trust?

Beneficial ownership is defined in the AML/CTF Rules as the natural persons who ultimately own or control an entity, whether directly or indirectly. For companies, a beneficial owner is typically any individual who holds 25% or more of the shares or voting rights, or who otherwise exercises effective control — including through a chain of ownership. For discretionary trusts, beneficial owners include the settlor, each trustee, and any identified or identifiable class of beneficiaries. For SMSFs, each trustee and member must be identified.

Can an outdated company constitution or trust deed create an AML/CTF compliance problem?

Yes and it is one of the most commonly overlooked risks in accounting practice. Many clients have companies and trusts that were established years ago under older documents that have never been updated. The problem is that AUSTRAC requires you, as the reporting entity, to clearly identify who owns and controls every entity you act for — and if the governing documents do not support that identification, you have a compliance gap before you have even started. A company constitution that predates the Corporations Act 2001 (Cth), or one that was never properly adopted, may not accurately reflect how the company is actually governed. A trust deed that does not clearly name the settlor, trustee, and class of beneficiaries leaves you unable to complete beneficial ownership mapping as required under Chapter 4 of the AML/CTF Rules. Inaccurate ASIC records — wrong members, outdated officeholders, missing share transfers — compound the problem further. AUSTRAC has specifically flagged these as primary CDD red flags in its Professional Services Core Guidance.

What is a Politically Exposed Person and how does this affect company and trust registrations?

A Politically Exposed Person (PEP) is defined in the AML/CTF Rules as a person who holds, or has held in the past four years, a prominent public position — including heads of state, government ministers, senior officials, judges, senior military officers, and executives of state-owned enterprises — along with their immediate family members and known close associates.

Should I seek legal advice?

The summary displayed on this page is for information purposes only. Summary for share buy back should be considered general in nature, and should not be a substitute for professional legal advice. You must always seek your own independent legal, financial and accounting advice about your unique situation.

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