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Does Your Business Provide a Designated Service? Here’s How to Tell

From 1 July 2026, Australia’s expanded anti-money laundering and counter-terrorism financing laws will apply to certain services commonly provided by real estate professionals, lawyers, conveyancers, accountants, trust and company service providers and dealers in precious metals, and goods.

However, simply working in one of these industries does not automatically mean your business is regulated. Your obligations depend on the specific services you provide.

So, what are designated services, and how can you tell whether your business is captured?

What Are Designated Services?

A designated service is a particular type of business activity listed under Australia’s Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

These services may involve:

  • Buying or selling property for a client
  • Handling or transferring client funds
  • Establishing companies, trusts or other legal structures
  • Managing a company’s assets or bank accounts
  • Arranging changes in business ownership
  • Providing nominee director, shareholder or office services

The key point is that AML/CTF obligations are based on the service being provided, not just your business name, profession or industry category.

When reviewing AML/CTF designated services in Australia, businesses need to look closely at what they actually do for clients.

Examples of Designated Services by Industry

1. Real estate professionals

Real estate agents, buyer’s agents and property developers may be captured when they represent clients in the purchase or sale of real estate.

A business that only provides general property advice or advertising may be treated differently from one that actively represents a buyer or seller in a transaction.

Learn more about AML/CTF compliance for real estate professionals.

2. Lawyers and conveyancers

Property lawyers, corporate lawyers, conveyancers and settlement agents may provide designated services when they assist with property transactions, manage client money, establish companies or trusts, or arrange ownership structures.

Legal services such as litigation or advice unrelated to a designated transaction may not necessarily be captured.

3. Accountants and business advisers

Accountants, tax advisers, bookkeepers and financial consultants may be regulated when they establish companies or trusts, manage client assets, arrange business transactions or provide certain trust and company services.

Preparing a tax return by itself may not be a designated service. However, establishing a company or trust for the same client may create AML/CTF obligations.

4. Trust and company service providers

Company formation services and corporate structuring firms may be captured when they form companies, provide registered offices, arrange nominee services or manage legal entities on behalf of clients.

5. Precious metal dealers and jewellers

Dealers in precious metals, and products may be captured when they buy or sell items such as gold, silver, bullion, jewellery, precious stones or similar products for $10,000 or more in physical currency or virtual assets.

A jewellery store that only accepts standard card payments for lower-value retail sales may be treated differently from a dealer accepting high-value cash or virtual asset transactions.

Why Do Designated Services Trigger AML Obligations?

Property transactions, companies, trusts and complex ownership arrangements can be misused to hide criminal funds or conceal the identity of the people who control assets.

Because of these risks, businesses providing designated services may need to:

  • Verify customer identities through KYC or KYB checks
  • Identify beneficial owners
  • Assess customer and business-wide risk
  • Monitor customers and transactions
  • Recognise and report suspicious activity
  • Train relevant employees
  • Maintain complete compliance records

These controls help businesses identify unusual activity and reduce the risk of their services being used for financial crime.

Tranche 2 Designated Services Explained

The term Tranche 2 designated services refers to newly regulated activities commonly provided by legal, accounting, conveyancing, real estate, trust and company service professionals and dealers in precious metals, and products.

The new obligations begin on 1 July 2026.

Not every lawyer, accountant, real estate agency or business consultant will be regulated in exactly the same way. Two businesses in the same industry may have different obligations because they provide different services.

The right question is not only, “What industry is my business in?” It is, “Does my business provide a regulated service?”

Does My Business Need AUSTRAC Enrolment?

Businesses generally need to enrol with AUSTRAC if they provide a designated service that has a geographical link to Australia.

To assess your position, review your service list and identify whether your business:

  • Represents clients in property sales or purchases
  • Receives, holds or transfers client money
  • Creates companies, trusts or legal arrangements
  • Manages client assets or bank accounts
  • Arranges business ownership changes
  • Provides nominee or registered office services

If your business provides a designated service, you should prepare your AML/CTF framework and apply for AUSTRAC enrolment. Enrolment opened on 31 March 2026 and must be completed by 29 July 2026.

Because the rules depend on the details of each service, businesses should review AUSTRAC guidance or obtain independent professional advice when their position is unclear.

Buys or sells precious metals, stones or products for $10,000 or more in physical currency or virtual assets.

What Should Your Business Do Next?

Start by documenting every service your business provides. Then identify which services involve property, client funds, companies, trusts, business ownership, asset management, or high-value precious metal, stone or product transactions.

Your next steps may include:

  1. Applying for AUSTRAC enrolment
  2. Appointing an AML/CTF compliance officer
  3. Completing a business-wide risk assessment
  4. Developing an AML/CTF program
  5. Establishing KYC and KYB procedures
  6. Training relevant employees
  7. Setting up monitoring and reporting processes
  8. Maintaining audit-ready records

Waiting until a client transaction is underway can place unnecessary pressure on your team. Preparing early gives your business time to establish practical processes and train staff properly.

How Syntrico AML Guardian Helps

Managing designated services AML requirements through spreadsheets, emails and separate documents can quickly become difficult.

Syntrico AML Guardian brings your core AML/CTF processes together in one platform. It helps Australian businesses:

  • Build an industry-specific AML/CTF program
  • Complete business-wide and customer risk assessments
  • Conduct KYC and KYB verification
  • Identify beneficial owners
  • Screen customers for sanctions, PEP and adverse media risks
  • Monitor customers and transactions for red flags
  • Manage staff training
  • Prepare suspicious matter reporting information
  • Maintain clear, audit-ready compliance records

Instead of building every process from scratch, your business can follow guided workflows and keep important compliance evidence in one secure location.

Understanding whether you provide a designated service is the first step. The next is putting the right systems in place before your obligations begin.Prepare for Tranche 2 with Syntrico AML Guardian. Book a demo today!