AUSTRAC Clarifies AML/CTF Scope for Professional Services

AUSTRAC updated its guidance on professional designated services on 18 September 2026, providing further clarity on the activities covered by Table 6 of Australia’s Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

The guidance applies to a range of professional services, including assisting with real estate transactions, transferring companies or legal arrangements, managing client property, arranging equity or debt financing, creating or restructuring corporate entities or legal arrangements, providing nominee services, and supplying registered office or principal place of business addresses.

Under the updated guidance, businesses providing a designated service with a geographical link to Australia have AML/CTF obligations. This includes requirements to enrol with AUSTRAC and complete relevant customer due diligence before providing a designated service, subject to applicable exceptions.

When professional services become regulated

AUSTRAC emphasises that simply advising on or influencing a transaction does not necessarily make a service subject to AML/CTF requirements. The activity generally needs to directly advance a relevant transaction or the creation or restructuring of a corporate body or legal arrangement.

For example, general advice about establishing a trust would not necessarily constitute a designated service. However, drafting the trust deed and taking steps that directly create the trust can bring the activity within the regulated scope.

The same distinction applies to financial transactions. A professional providing general advice about financing a business would not necessarily be providing a designated service. Once the professional begins organising, negotiating or executing a specific equity or debt financing transaction, the activity can fall within the AML/CTF framework.

Compliance implications

The clarification is particularly relevant for firms that perform multiple professional functions, as the same business may provide both regulated and non-regulated services.

AUSTRAC states that AML/CTF obligations for Table 6 designated services apply from 1 July 2026. Businesses must therefore assess their services based on the activities they actually perform rather than relying solely on their professional designation.

The guidance also highlights that professional services can create money laundering, terrorism financing and proliferation financing risks, particularly where businesses facilitate transactions, control client assets or establish corporate and legal structures.

For regulated professional service providers, understanding exactly when an activity becomes a designated service will be important for determining when customer due diligence and other AML/CTF controls need to be applied.