Designated services under Tranche 2: am I in scope?
Overview. Tranche 2 captures your firm by the specific service you provide, not by your profession. You become a reporting entity only for the "designated services" you actually deliver, where your assistance directly advances a relevant transaction. Common work such as general tax advice, preparing tax returns, audit and bookkeeping does not, on its own, capture you.
This article is general information, not legal advice. Confirm your own situation against the live AUSTRAC guidance and its self-assessment tool. IdentityCheck helps you meet several of these obligations; it does not by itself make your firm compliant.
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Designated services, not professions
A designated service is a specific activity written into Australia's AML/CTF law that brings the business providing it into the regime. The key idea, and the one most people get wrong, is that the law regulates services, not professions. Being an accountant, a lawyer or a conveyancer does not automatically capture you. Providing a listed designated service does.
There is also a test of degree. A service is captured only when your assistance "directly advances" a relevant transaction, not when your advice merely informs the client about it. Explaining the tax consequences of a property sale is different from acting to help complete that sale. The first is advice; the second may be a designated service.
Because of this, two firms in the same profession can have very different obligations. One may provide several designated services and be firmly captured. Another may do none and sit outside the regime. This is why you assess your own service mix rather than assuming your profession decides it for you.
Accountants: which work is captured
Not automatically, and not for everything you do. Accountants are captured only for the designated services they provide. Typical captured activities include helping a client buy, sell or transfer real estate, helping buy or sell a business or other legal arrangement, holding or managing client money, selling shelf companies, creating or restructuring companies or trusts, and acting as (or arranging) a nominee director, shareholder or registered-office provider.
If you do provide one or more of these, you must identify and verify the customer before you provide that service, along with your other obligations. If your work is limited to general tax advice, preparing tax returns and audit, those activities do not, on their own, make you a reporting entity.
The practical step is to list the services your firm actually delivers and check each one against the designated-service list, rather than making a single yes or no call for the whole practice.
Bookkeeping
Bookkeeping on its own does not make a firm a reporting entity. Like general tax work, it sits outside the designated-service list when it stands alone. That is the reassuring part for many practices.
The caution is that some firms describe themselves as bookkeepers but also do work that is captured. If you hold or manage client money, or you help set up or restructure companies or trusts, that specific service can bring you into scope even though your day-to-day label is "bookkeeper". The regime looks at what you do, not what you call yourself. Assess each service line separately.
Lawyers and conveyancers
Lawyers and conveyancers are captured when they provide a designated service. Common examples include helping buy, sell or transfer real estate, helping buy or sell a body corporate or legal arrangement, holding or managing client money, and acting as (or arranging) a nominee director, shareholder or registered-office provider.
General legal advice that only informs a client, without your firm acting to advance the transaction, is not a designated service on its own. As with accountants, the sensible approach is to map your matters against the designated-service list and treat the captured ones accordingly.
Who else is in scope
Tranche 2 also captures real estate professionals (agents, buyer's agents and property developers brokering sales, purchases or transfers of real estate) and dealers in precious metals, stones and products where payment involves physical currency or virtual assets totalling AUD $10,000 or more. Expanded virtual-asset services are covered too. If any of these describe part of your business, the same "designated service" logic applies.
How to check your own situation
The most reliable way to settle this for your firm is AUSTRAC's own "check if you may be regulated" self-assessment tool. It walks you through the questions that decide whether the services you provide bring you into the regime. Use it as your starting point, and keep a record of your assessment.
It is also worth remembering that Tranche 2 is not the only reason to verify who your clients are. Accountants and tax agents already have client-verification duties under their ATO and Tax Practitioners Board (TPB) obligations, which include proof-of-identity requirements for the clients they act for. So even where a service sits outside Tranche 2, verifying client identity is generally still expected of a tax practitioner. Confirm your specific duties against the TPB and AUSTRAC references below.
Frequently asked
Do accountants have to do KYC now? Only if you provide a designated service. Accountants are captured when a service directly advances a relevant transaction, for example helping buy, sell or transfer real estate or a business, holding client money, or creating or restructuring companies or trusts. General tax advice, tax returns and audit do not, on their own, capture you.
Is bookkeeping captured? Bookkeeping on its own does not make a firm a reporting entity. Tranche 2 captures specific designated services, not entire professions. If your bookkeeping work extends into holding or managing client money, or into setting up or restructuring companies or trusts, that specific service may be captured. Check your own facts against the AUSTRAC tool.
Do lawyers and conveyancers need AML checks? Lawyers and conveyancers are captured when they provide a designated service, such as helping buy, sell or transfer real estate, buying or selling a business or legal arrangement, holding client money, or acting as a nominee director or shareholder. General legal advice that only informs a client is not captured on its own.
What is a designated service? A designated service is a specific activity listed in the AML/CTF law that brings a business into the regime. It is the service, not the profession, that is captured. A service counts when your assistance directly advances a relevant transaction, not when your advice merely informs the client.