Course overview

This course introduces the regulatory and risk foundations of Australia’s expanded AML/CTF regime for accounting practices. It focuses on when accountants enter the regulated perimeter, how money laundering and terrorism financing risk appear in accounting workflows and how practitioners apply defensible professional judgement when client facts are incomplete, urgent or commercially sensitive.

The course is designed for accountants, BAS agents, tax practitioners, practice leaders and compliance staff who need to understand the upcoming AML/CTF obligations and the risk judgment expected in professional services.

Course objectives

Explain the AML/CTF regulatory perimeter for accountants and identify when accounting work moves into designated-service territory.
Recognise money laundering and terrorism financing typologies relevant to entity structuring, client-money handling, trusts, companies, property, financing and cross-border arrangements.
Apply customer due diligence, enhanced due diligence, ongoing monitoring and escalation logic to realistic accounting-practice scenarios.
Integrate AML/CTF obligations with APES 110, NOCLAR, APES 220, APES 310 and TPB conduct expectations.
Make defensible decisions about acceptance, continuation, reporting, client communication, disengagement and recordkeeping.

Learning outcomes

By completing this course, you should be able to:

Distinguish general professional advice from regulated implementation work that may trigger AML/CTF obligations.
Identify structural, transactional, cross-border, PEP, sanctions and client-money risk indicators in accounting workflows.
Assess when unusual facts require enhanced due diligence, escalation, suspicious matter reporting or disengagement.
Communicate with clients in a way that supports compliance without creating tipping-off risk.
Document AML/CTF and professional judgement decisions so the file shows a clear, defensible reasoning pathway.

Lesson overview

Lesson	Lesson title	Overview
1	Entering the regime: perimeter, obligations, and professional judgement	Establishes the legal perimeter, designated-services boundary, commencement readiness, CDD and reporting logic, and the professional standards that shape accountant judgement.
2	Detecting ML/TF in accounting workflows	Develops detection capability across structural typologies, beneficial ownership, client-money flows, property and business transfers, cross-border risks, PEP exposure and escalation from anomaly to suspicion.
3	Applying AML judgement in practice	Applies the framework to acceptance, continuation, ECDD, suspicion thresholds, tipping-off-safe communication, disengagement, defensible documentation and escalation protocols.

CPD compliance mapping

This course is designed to support professional development for accountants, BAS agents, tax practitioners, practice leaders and compliance staff who need to understand Australia’s expanded AML/CTF regime and its practical implications for accounting services. The course aligns with continuing professional development and continuing professional education expectations because it develops technical knowledge, ethical judgement, professional competence, risk awareness and practical compliance capability.

The course is particularly relevant to practitioners who provide, or may provide, designated professional services under the expanded AML/CTF framework. It also supports accountants who need to understand how AML/CTF obligations interact with APES 110, APES 220, APES 310, NOCLAR principles, client-money obligations, Tax Practitioners Board conduct requirements and professional judgement in client acceptance, continuation, escalation and documentation.

Course relevance to professional body CPD and CPE expectations

Professional body or framework	Relevant CPD or CPE alignment	How does this course support the requirement
CPA Australia	Supports CPD directed to maintaining professional competence, technical knowledge, ethical conduct and public interest obligations. The course may also support ethics-related CPD where the learner’s role involves client acceptance, professional judgement, compliance, governance or risk management.	The course develops practical competence in identifying AML/CTF risk, applying ethical judgement, recognising conflicts between client instructions and professional obligations, and documenting defensible decisions. It also addresses integrity, professional behaviour, governance, risk culture and escalation.
Chartered Accountants Australia and New Zealand	Supports CPD directed to maintaining competence, providing high-quality professional services and upholding public trust. The course may support verifiable CPD by retaining completion evidence, and may contribute to ethics-related CPD by requiring learners to apply APES 110 and professional judgement.	The course strengthens competence in a major regulatory reform affecting accounting practice. It develops the learner’s ability to distinguish between advice and regulated implementation, identify client and transaction risks, apply CDD and ECDD, and make ethically supportable decisions under pressure.
Institute of Public Accountants	Supports CPD across technical and product knowledge, management and professional skills, and professional and ethical standards.	The course addresses technical AML/CTF obligations, operational risk controls, professional judgement, client-money risks, escalation protocols and ethical conduct. It is suitable for practitioners who need to build capability across compliance, governance and professional standards.
Tax Practitioners Board	Supports CPE where the content is relevant to tax agent or BAS agent services and assists practitioners to maintain knowledge and skills relevant to the services they provide.	The course connects AML/CTF risk with tax and BAS practice, including false or misleading statements, reasonable care in ascertaining client circumstances, proper records, client-money risks, and escalation where suspicious conduct intersects with tax reporting or advisory work.
APES 110 Code of Ethics for Professional Accountants	Supports development of professional competence and due care, integrity, objectivity, confidentiality and professional behaviour. It also supports an understanding of NOCLAR obligations when suspected non-compliance arises.	The course applies APES 110 to realistic AML/CTF scenarios, including opaque ownership, client money movement, suspicious transaction patterns, pressure to proceed quickly, confidentiality limits, tipping-off risk, and disengagement decisions.
APES 220 Taxation Services	Supports ethical and professional application of taxation services, particularly where tax advice, BAS work, payroll, structuring or client records may intersect with suspicious conduct.	The course helps learners recognise when tax-related information, transaction narratives, related-party arrangements, payroll flows, capital injections or client explanations may require further enquiry, escalation or refusal to act.
APES 310 Client Monies	Supports professional judgement in relation to the receipt, holding, control and disbursement of client money.	The course examines client-money risk, pass-through accounts, third-party payments, refund redirections and source-of-funds concerns. It helps learners understand why client money handling is a significant AML/CTF risk point for accounting practices.
AUSTRAC AML/CTF expectations for accountants	Supports readiness for AML/CTF obligations applying to accountants who provide designated services, including enrolment, AML/CTF program readiness, staff training, ML/TF risk assessment, CDD, suspicious matter reporting and record keeping.	The course directly supports AUSTRAC-aligned capability by training learners to identify designated-service triggers, assess ML/TF risk, recognise suspicious activity indicators, apply CDD and ECDD, escalate unusual matters, avoid tipping off and document decisions in a defensible way.

Mapping of lessons to CPD and AUSTRAC capability areas

Lesson	Key capability developed	CPD or CPE relevance	AUSTRAC-aligned competency area
Lesson 1: Entering the regime: perimeter, obligations, and professional judgement	Understanding the AML/CTF perimeter, designated-service triggers, governance roles, CDD concepts, reporting logic and the ethical overlay.	Technical knowledge, regulatory compliance, ethics, governance and professional judgement.	Understanding whether the practice is regulated, identifying designated services, preparing for enrolment, applying an AML/CTF program, understanding CDD and reporting obligations.
Lesson 2: Detecting ML/TF in accounting workflows	Recognising structural, transactional, client-money, cross-border, PEP, sanctions and beneficial ownership risk indicators in accounting work.	Technical competence, risk identification, client advisory judgement, fraud awareness, ethics and professional scepticism.	Conducting ML/TF risk assessment, recognising suspicious activity indicators, understanding client and service risk, identifying foreign jurisdiction risk and escalating unusual activity.
Lesson 3: Applying AML judgement in practice	Applying acceptance, continuation, ECDD, suspicion assessment, tipping-off-safe communication, disengagement and documentation decisions.	Professional judgement, ethics, governance, client engagement management, risk controls and defensible documentation.	Applying internal processes, escalating risk, deciding whether suspicion exists, reporting suspicious matters, avoiding tipping off, training staff in operational decision-making and maintaining records.

Suggested CPD classification

Classification field	Suggested course classification
CPD or CPE type	Verifiable CPD or CPE, subject to the learner retaining evidence of completion.
Professional area	Governance, ethics, professional standards, regulatory compliance and risk management.
Technical area	AML/CTF obligations, designated services, CDD, ECDD, suspicious matter reporting, beneficial ownership and client-money risk.
Ethics relevance	High, because the course applies integrity, objectivity, professional competence, due care, confidentiality, professional behaviour, NOCLAR and client acceptance judgement.
Practice management relevance	High, because the course addresses governance roles, escalation pathways, risk controls, documentation and workflow discipline.
Tax practitioner relevance	Moderate to high, depending on the practitioner’s service profile, because AML/CTF risk may arise through tax planning, BAS work, payroll, business restructuring, false or misleading statements and client records.
AUSTRAC readiness relevance	High for practices that provide or may provide designated services under the expanded AML/CTF regime.

Abbreviations and their meanings

Abbreviation	Meaning
AML	Anti-money laundering
CTF	Counter-terrorism financing
AML/CTF	Anti-money laundering and counter-terrorism financing
ML/TF	Money laundering and terrorism financing
PF	Proliferation financing
AUSTRAC	Australian Transaction Reports and Analysis Centre
CDD	Customer due diligence
EDD	Enhanced due diligence
ECDD	Enhanced customer due diligence
SMR	Suspicious Matter Report
TTR	Threshold Transaction Report
PEP	Politically exposed person
BO	Beneficial ownership
APESB	Accounting Professional and Ethical Standards Board
NOCLAR	Non-compliance with laws and regulations
FATF	Financial Action Task Force
NSWCCA	New South Wales Court of Criminal Appeal