You may have noticed us asking a few more questions lately. Where a payment has come from, how your business is structured, who’s involved in a particular deal. We wanted to explain why, because it’s not us being suddenly suspicious. Australia has updated its money laundering laws, and from 1 July 2026 those rules reach accountants for the first time. So this is us giving you the heads-up, the way we’d want it given to us.
The changes come from the Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill, which passed Parliament in November 2024, with the supporting rules tabled in August 2025. They’re the biggest shift in this area in close to twenty years. The laws already applied to banks and payment providers, and now a new group of professions is being brought into the same fold.
Who the rules now cover
For a long time these obligations sat almost entirely with financial institutions. The second stage of reform, often called Tranche 2, widens things from 1 July 2026 to include accountants, lawyers, real estate agents, property developers, and dealers in precious stones and metals.
Any business newly captured by the rules needs to enrol with AUSTRAC by 29 June 2026 and meet its obligations under the Act from 1 July 2026. There’s a separate timeline for businesses already inside the regime, who need most of their updates in place by 31 March 2026.
How this shows up in our work together
Most of the change lives inside the due diligence process, which is a formal way of saying we match the level of checking to the level of risk. If you’re a client with a clear, well-documented position, you sit at the simpler end and you’ll barely feel the difference. Closer attention only comes into play where the situation genuinely calls for it.
In everyday terms, we’ll need to confirm who you are, and in some cases understand where the funds in a transaction have come from. For most of the people we work with, this is quick and painless. If we’ve known you and your numbers for a while, much of this is already on file and you won’t have to do anything new.
The moments where you might field a few more questions tend to be the ones with more moving parts. Complex group structures, trusts with several beneficiaries, the sale or purchase of a business, property deals, or any time someone outside the immediate relationship is funding or directing a transaction. None of that means we think something is wrong. It simply means the rules ask us to look a little more closely when the stakes are higher.
Here’s the honest reason behind all of it. Investigations over the years have shown that advisers can end up tangled in money laundering schemes without ever knowing it happened. These laws exist to stop that, by making sure people like us truly understand who we’re working with and what we’re being asked to do. We’re glad to take it seriously, because building these checks into how we work protects you every bit as much as it protects us.
What we’re putting in place
As a reporting entity, we’re required to assess the money laundering and terrorism financing risks tied to the services we offer, write and follow policies that manage those risks, complete customer due diligence before we begin regulated work, and appoint a compliance officer to keep an eye on the day-to-day side of it.
We’ve started early and we’re working through all of it well ahead of the deadlines, so that the effect on your experience with us stays as gentle as possible. AUSTRAC has made it clear it wants compliance to be straightforward for small, lower-complexity businesses, and that it’s aiming to keep the whole thing efficient and affordable for practices already carrying other regulatory duties. That’s exactly the spirit we’re bringing to it internally.
If you run a creative business or agency
Many of the people we work with operate through a company or trust, bring in project funding from a range of sources, or move money across borders for international work and collaborations. If that’s you, it’s worth a short, relaxed chat about how these rules touch your engagement with us. We’d rather talk it through together than have any of it land as a surprise. The questions are never a sign that something is off. They’re simply part of a framework that now applies across every client relationship, scaled to the risk attached to the services involved.
We may ask for refreshed identification, details about who ultimately owns or controls an entity, or paperwork showing where the funds in a particular transaction came from. If you’re a freelancer or small studio with a simple setup, the touch will be light. If you’re a larger production company or agency handling client money or acquisitions, expect us to be a little more thorough with the paperwork, and know that we’ll make it as easy as we can.
One detail worth being aware of, shared in the spirit of keeping you informed rather than worried. Civil penalties under the AML/CTF Act can apply to individual directors and officers, not only the company itself. So the obligations reach a little further than just us, which is part of why our record-keeping will be more careful from here on.
The dates that matter
Two milestones anchor the timeline. Businesses already regulated, the banks and financial institutions, needed their updated frameworks ready by 31 March 2026. Accountants (us), lawyers, and real estate agents joining as Tranche 2 professions must be enrolled with AUSTRAC by 29 June 2026 and fully compliant by 1 July 2026.
If you’d like to understand how any of this applies to you, or what we might need from you, have a word with your Count Out Loud adviser whenever it suits. A friendly conversation now is so much nicer than a scramble later in the year, and we’re always happy to walk you through it.