On 1 July 2026, the AML/CTF regime was extended to a variety of Tranche 2 services. Under Table 6 of section 6 of the AML/CTF Act, there are a range of “professional services” which are included as designated services. Professional services are primarily provided by accountants, lawyers and real estate agents, and AUSTRAC has targeted these types of professional service providers in its guidance and its use of generic descriptions to label these services. However, the professional services which are listed in Table 6 could also be provided by other types of entities. For further information about professional services and how existing reporting entities may be providing these types of services, please see our earlier blog.
It’s important for all businesses, both existing reporting entities and also businesses that consider they may be caught by the extended regime, to understand how:
This is important in terms of:
New and existing reporting entities alike are required to complete an AUSTRAC Business Profile Form which specifies the types of designated services the entity provides. Both new and existing reporting entities must have advised AUSTRAC by 1 July 2026 of any designated services listed in Table 6 that they provide.
The table below lists the specific designated services (as defined in Table 6) and the matching description in the AUSTRAC Business Profile Form.
| Item | Provision of Designated Service | AUSTRAC Business Profile Form Description |
|---|---|---|
| 1 | assisting a person in the planning or execution of a transaction, or otherwise acting for or on behalf of a person in a transaction, to sell, buy or otherwise transfer real estate, where: (a) the service is provided in the course of carrying on a business; and (b) the sale, purchase or other transfer is not pursuant to, or resulting from, an order of a court or tribunal | Conveyancing services |
| 2 | assisting a person in the planning or execution of a transaction, or otherwise acting for or on behalf of a person in a transaction, to sell, buy or otherwise transfer a body corporate or legal arrangement, where: (a) the service is provided in the course of carrying on a business; and (b) the sale, purchase or other transfer is not pursuant to, or resulting from, an order of a court or tribunal | Buying, selling, or transferring a company or legal entity |
| 3 | receiving, holding and controlling (including disbursing) or managing a person’s: (a) money; or (b) accounts; or (c) securities and securities accounts; or (d) virtual assets; or (e) other property; as part of assisting the person in the planning or execution of a transaction, or otherwise acting for or on behalf of a person in a transaction, in the course of carrying on a business (other than in a circumstance covered by subsection (5C)) | Asset management |
| 4 | assisting a person in organising, planning or executing a transaction, or otherwise acting for or on behalf of a person in a transaction, for equity or debt financing relating to: (a) a body corporate (or proposed body corporate); or (b) a legal arrangement (or proposed legal arrangement); in the course of carrying on a business | Facilitating business equity and debt financing |
| 5 | selling or transferring a shelf company, in the course of carrying on a business | Shelf company services |
| 6 | assisting a person to plan or execute, or otherwise acting on behalf of a person in, the creation or restructuring of: (a) a body corporate (other than a corporation under the Corporations (Aboriginal and Torres Strait Islander) Act 2006); or (b) a legal arrangement; in the course of carrying on a business | Business structuring services |
| 7 | acting as, or arranging for another person to act as, any of the following, on behalf of a person (the nominator), in the course of carrying on a business: (a) a director or secretary of a company; (b) a power of attorney of a body corporate or legal arrangement; (c) a partner in a partnership; (d) a trustee of an express trust; (e) a position in any other legal arrangement that is functionally equivalent to a position mentioned in any of the above paragraphs; other than in a circumstance covered by subsection (5E) | Facilitating or performing roles in corporate/legal arrangements |
| 8 | acting as, or arranging for another person to act as, a nominee shareholder of a body corporate or legal arrangement, on behalf of a person (the nominator), in the course of carrying on a business | Nominee shareholder services |
| 9 | providing a registered office address or principal place of business address of a body corporate or legal arrangement, in the course of carrying on a business | Providing registered or principal address services |
Sophie Grace can provide you with an AML/CTF Program and can assist you to tailor it to your business’ needs. We have three different options available to suit your business and finance needs.
You can purchase template documents from our online shop. The template is an instant download and includes prompts to help you tailor the document yourself. We have template documents for:
Sign up to the Compliance Portal and receive the template AML/CTF Program Package, and obtain access to updated documents in light of any updates we make as new guidance or amended legislation is released. Choose between:
Sophie Grace can assist you to prepare the AML/CTF Program package based on your business’ specific requirements. Contact us to discuss further.
Find everything you need in relation to the AML/CTF Reforms
Sign up today for up-to-date compliance policies and regular consultation with our staff. Watch our demonstration video now!
We will get in touch as soon as possible
