Tranche 2 and your accounting practice: which services are captured

Your practice is probably part-captured, not fully captured

Most accounting practices reacting to Tranche 2 ask whether accountants are in scope. It is the wrong question, and it leads to two expensive mistakes: building a compliance program far bigger than the practice needs, or assuming general practice work keeps you out entirely.

Capture is service-based. A practice that files tax returns and gives business advice may provide no designated services at all. The same practice, the moment it starts incorporating companies for clients or acting as a trustee, is providing designated services and is a reporting entity.

The services most likely to capture an accounting practice

The designated services that most commonly bring accounting practices into scope cluster around structuring, control and money:

• Forming companies, trusts, partnerships or other legal arrangements for a client.
• Acting as, or arranging for another person to act as, a director, secretary, trustee or nominee shareholder.
• Providing a registered office or business address for a company or other structure.
• Receiving, holding, controlling or paying out client money in connection with a transaction.
• Assisting a client to plan or execute the buying or selling of a body corporate or business.
• Assisting with the transfer of real estate.

What usually stays outside

Preparing and lodging tax returns, general bookkeeping, audit and assurance work, and broad business or financial advice are not, on their own, designated services. Practices that stay strictly within that work may find they provide no designated services at all.

The catch is that very few practices stay strictly within it. A single company incorporation a year is still a designated service, and the obligations follow the service, not its frequency.

Work out your exposure by service line, not by department

The practical exercise is to list every service line the practice bills for, and mark each one against the designated services in the AML/CTF rules. That gives you three things: whether you are captured at all, which parts of the practice carry the obligation, and a defensible written record of how you reached that view.

That last point matters more than firms expect. If your position is that a service line sits outside the regime, you want the reasoning documented at the time, not reconstructed later.

If you are captured

The obligations are the same regardless of how much of your practice is in scope: enrol with AUSTRAC, complete a risk assessment, document an AML/CTF program approved by senior management, appoint a compliance officer, run customer due diligence, monitor and report, train your people, and keep records for seven years.

The proportionality sits in how you apply them, not in whether they apply. A practice with one captured service line can run a much lighter program than a full trust and company service provider — but it still needs a program, and it still needs to show its work. True Comply helps practices confirm where they stand and build a program sized to the exposure they actually have. Start the conversation and we will help you map it.