From July 2026, Australia will introduce significant updates to its Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) laws.
As part of these reforms, accounting and advisory firms, including Armada, will come under the AML/CTF Act and be supervised by AUSTRAC. This means there will be some changes in how we work with you.
These updates are particularly relevant if you are:
- Establishing, restructuring, buying, or selling companies, trusts, or SMSFs
- Involved in property transactions or moving funds between entities
- Operating a cash intensive, international, or higher risk business
- Implementing complex structures or highvalue transactions
- Running a Professional Services Business
These reforms are aimed at preventing criminals from misusing professional services. While this is not something that affects the vast majority of clients, the law requires all firms, including Armada, to apply the same checks consistently.
Professions such as accountants, lawyers, real estate agents, and trust and company service providers will now have these rules applied because they can:
- Set up companies and trusts
- Assist with moving money between entities
- Structure transactions
- Handle client funds
- Provide commercial legitimacy to financial arrangements
To protect the integrity of the financial system, the new laws require stronger checks before certain services can be provided.
What Armada Will Be Required to Do
Under the new framework, we will need to:
1. Verify Identify and Ownership
We must confirm the identity of our clients and, where relevant, identify the beneficial owners of companies, trusts, and other entities.
These checks are standard and apply to all clients, not because of any concern about your activities.
2. Understand the Purpose of Transactions
For certain services, we will need to understand the commercial purpose behind a transaction or structure.
This helps us demonstrate to regulators that legitimate transactions are exactly that.
3. Apply Risk-Based Checks
Some industries and activities are considered higher risk (for example, cash heavy businesses or crypto related activities).
Where this applies, we must complete additional due diligence, not because we suspect wrongdoing, but because the law requires it.
4. Monitor for Unusual Activity
We are required to follow up on transactions that appear inconsistent or unusual.
Examples include:
- Unexplained cash deposits
- Rapid movement of funds between related entities
- Clients declining to provide ID
- Complex structures with no clear commercial purpose
These examples are part of the legislation’s guidance. They rarely arise with our clients, but if they do, we are required to ask questions and document the explanation.
5. Report Suspicious Matters
If something raises serious concerns, we are legally required to lodge a Suspicious Matter Report with AUSTRAC, even if no wrongdoing is ultimately found.
This is a mandatory obligation for all accounting firms.
6. Maintain Detailed Records
We must keep clear records of identity checks, risk assessments, and monitoring activities.
7. Ensure Contractors Follow the Same Standards
If we use outsourced or offshore team members, Armada remains responsible for ensuring all AML requirements are met.
Even where no suspicious activity occurs, not having the right systems and documentation in place can still lead to regulatory action. This is why we must apply these processes consistently across all clients.
What We May Need From You
From time to time, we may need additional information or documentation from you. This could include:
- Updated identification documents
- Details of directors, shareholders, trustees, or beneficial owners
- Explanations for certain transactions or fund movements
- Supporting documents for complex or high value transactions
- Additional onboarding information for new entities
- More detailed information about business activities
These requests are not a reflection on you or your business. They are simply part of the new compliance framework that all firms must follow.
If you are establishing a new company, trust, or SMSF, we will need to complete identity and ownership checks before we can proceed.
If you are buying or selling a business, restructuring entities, moving funds between related entities, or handling settlement funds, additional checks may apply.
If we notice transactions that appear unusual, such as large cash deposits, rapid fund movements, round number transfers, or overseas payments without a clear purpose, we are required to ask questions and document the explanation.
Again, this is a legal requirement, not an indication of concern.
Why This Matters
These changes are not about adding unnecessary red tape. They are designed to protect:
- The integrity of Australia’s financial system
- You and your business from reputational or regulatory risk
- Armada and all other professional advisors
We understand that some of these requests may feel new or unexpected and our clients are overwhelmingly doing the right thing, however these processes simply help us demonstrate that to the regulators.
We are working to make this transition as smooth and practical as possible. Our internal systems are being updated now so that compliance is efficient, secure, and minimally disruptive for you.
If you have any questions about how these changes may affect you or your business, we are always here to help.