‘Are we even captured?’ How AML/CTF scope really works

Scope follows the service, not the job title

One of the most common misunderstandings about Tranche 2 is that whole professions have been “brought in”. That's not quite how the regime works. Capture is service-based: it depends on whether you provide a designated service, not on what your business card says.

This distinction matters, because two businesses with the same job title can have very different obligations depending on what they actually do for clients.

Some examples

An accountant who only provides general tax or financial advice may sit outside the regime, while an accountant who helps set up companies or trusts, or manages client money, may be providing designated services. A real estate business that sells and transfers property for clients is likely captured, while activity limited to property management and leasing generally is not. A lawyer handling a property or business transaction may be in scope in a way that a lawyer running a court dispute is not.

In each case, the question is the same: which specific services do we provide, and are any of them designated services?

Why it's worth getting right

Over-assuming scope wastes effort on obligations that may not apply to you. Under-assuming it leaves you exposed, because the obligations applied from 1 July 2026 whether or not a business realised it was captured. A careful look at your service lines is the way to land in the right place.

How to work it out

Map your service lines against the designated services in the AML/CTF rules, and get advice where it's genuinely unclear — the edges can be finely balanced. True Comply helps regulated businesses confirm where they stand and, where they are captured, build the program to match. If you're not sure, start the conversation and we'll help you work it out.