AUSTRAC Clarifies Professional Services Scope Under Australia’s Expanded AML/CTF Regime

AUSTRAC has updated its guidance for professional designated services, adding further detail on when professional-service activities fall within Australia’s expanded anti-money laundering and counter-terrorism financing regime.

The regulator recorded the update on 3 September 2026. It adds more context on the scope of the item 9 designated service and clarifies the meaning of “registered office address” and “principal place of business address”. The change is part of AUSTRAC’s continuing implementation guidance for newly regulated professional-service sectors.

Further clarification for professional-service providers

The September update follows several earlier changes to the professional designated services guidance. On 31 August, AUSTRAC added guidance on how licence-to-occupy and leasehold arrangements are treated under the AML/CTF regime, as well as a new example involving notaries and notarial services to help businesses assess whether their activities constitute professional designated services.

AUSTRAC also substantially expanded this guidance in June. Those changes provided more detail on when receiving, holding, controlling or managing another person’s money or property as part of a transaction may be a designated service; when statutory exclusions may apply; when certain filing, nominee, representative or procedural activities may fall outside specific designated-service provisions; and how the phrase “assisting or otherwise acting for or on behalf of a person” should be interpreted.

The regulator has also been updating implementation material across the wider AML/CTF reforms. Changes to program starter kits include revised guidance on beneficial ownership checks, stronger risk-assessment expectations, new risk information on artificial intelligence, decentralised finance and offshore virtual asset service providers, and updated compliance-reporting timeframes. AUSTRAC has told businesses that used earlier starter-kit documents to review the changes and update their AML/CTF programs where required.

Operational significance

The latest clarification is particularly relevant to legal, accounting, corporate and other professional-service providers assessing whether a specific service brings them within the reporting-entity regime. The important question is not simply the provider’s profession or business label, but whether the actual activity performed matches a designated service under the amended framework.

For firms preparing compliance programs, the continuing guidance changes mean service mapping should remain a live implementation task. Businesses should compare their actual activities against AUSTRAC’s updated examples and definitions rather than relying only on an earlier interpretation of the Tranche 2 reforms.