Anti Money Laundering & Counter Terrorism Financing
At Holman Hodge, trust and transparency sit at the centre of our client relationships. As part of this commitment, we want to explain some upcoming regulatory changes and what they may mean for you.
From 1 July 2026, Australian accounting and advisory firms are required to comply with enhanced Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws, overseen by AUSTRAC. These changes are part of a national reform designed to protect the integrity of Australia’s financial system and bring local regulations into line with international standards.
Under these laws, we may need to collect and verify certain client information, including identity details and information about business structures, ownership, and control. In some cases, this may extend to more detailed information, such as source of wealth and source of funds. These checks are not triggered by suspicion – they are standard legal requirements as part of the AML/CTF laws.
What this means in practice
Not all services we provide are affected.
The AML/CTF requirements apply only when we deliver certain services defined in the legislation as “designated services”. Many routine accounting and compliance services, such as preparing a standard tax return, are not designated services on their own.
Where a designated service applies, the law requires us to complete identification and other due‑diligence checks before we can proceed.
Examples of designated services
Designated services may arise as a component of a broader transaction or arrangement involving assets or legal structures. This can include helping with ownership, control, transfer or day-to-day administration. Examples include:
- Assisting with buying, selling, or transferring real estate
- Assisting with buying, selling, or transferring a company or trust
- Holding, managing, or controlling client money, accounts, or property
- Assisting with equity or debt financing transactions
- Creating or restructuring companies, trusts, or other legal arrangements
- Acting as (or arranging for someone to act as) a director, secretary, trustee, or partner on your behalf
- Providing a registered office or business address on behalf of a client
If you’re unsure whether a particular engagement is affected, we’ll talk this through with you.
Identity and information checks
Where required by legislation, we may ask for information such as:
- a current photo ID or other ID verification documents
- confirmation of personal or business details
- information about company directors, trustees or beneficial owners
- details about the source of funds and source of wealth for certain transactions
In many cases, we already hold much of this information. Our approach is to use what we have and only request what is missing or needs updating.
In some situations, additional information may be required because of the nature of the transaction or structure involved. Where applicable, the law requires us to ask about the source of funds for a transaction and how overall wealth has been accumulated. These are standard risk-assessment questions required by the legislation, and do not imply anything unusual.
What happens if information can’t be provided
If we’re unable to complete the required checks, the law may restrict our ability to provide certain services at that time. We will always explain what’s required and work with you to minimise disruption wherever possible.
Privacy and confidentiality
We take data security and confidentiality seriously. Any information collected for AML/CTF purposes is handled in accordance with privacy laws and stored securely. Records are retained only for the period required by law.
Ongoing obligations
Identity checks are largely a once off process. However, we are required to keep client information reasonably current and may ask for updates if circumstances change.
Our commitment to you
At Holman Hodge, our role is to guide you through regulatory change with clarity and care. If you have questions about how AML/CTF requirements apply to your circumstances, please speak with your usual adviser – we’re here to help make the process as straightforward as possible.