Plain-English guides to AUSTRAC and tranche 2, from Curlew Comply

ReferenceAccountants · 8 min read

The AML/CTF field guide for accountants

Everything an accounting practice needs at hand, designed to be printed once and kept. Not a course — a working reference.

By Amanda Dunn · 27 October 2026

FieldguideFORAccountants

This is the short version of everything on this site, arranged for the wall rather than the screen. Print it, fill in the last section with your own business details, and keep it where the phone is.

1 · The question, and the instruction

The question: am I, right now, setting up or restructuring a company or trust, acting as or arranging a nominee, providing a registered office, arranging financing, or receiving and holding client money? If so, the framework is in play — whatever your job title says.

Whether your particular business is captured, and which of its activities are caught, is a matter for AUSTRAC’s guidance or your own adviser. The question above is the one to carry around; the determination is not yours or ours to make.

The instruction: it is not your job to decide whether something is suspicious enough to report. It is your job to notice and escalate.

2 · The words

TermStands forIn plain English
AML/CTFAnti-Money Laundering / Counter-Terrorism FinancingThe framework that stops criminals using ordinary businesses to hide money or fund terrorism.
AUSTRACAustralian Transaction Reports and Analysis CentreAustralia’s financial intelligence agency, and your regulator.
CDDCustomer Due DiligenceWorking out who your client is, and recording how you know.
EDDEnhanced Due DiligenceDeeper checks for clients assessed as higher risk.
KYCKnow Your CustomerThe everyday name for the same practice.
ML/TFMoney Laundering / Terrorism FinancingThe two risks your risk assessment has to address.
UBOUltimate Beneficial OwnerThe actual human behind a company or trust.
PEPPolitically Exposed PersonSomeone in a prominent public position, plus close family and associates.
PDDPersonnel Due DiligenceChecks on your own people who hold AML/CTF responsibilities.
SMRSuspicious Matter ReportWhat the business files with AUSTRAC when something does not add up.
TTRThreshold Transaction ReportA report triggered by a large cash transaction. No suspicion needed.
CBMRCross-Border Movement ReportFor physical currency or bearer instruments crossing the border.
UARUnusual Activity ReportYour internal escalation. Whether it becomes an SMR is the officer’s call.
goAMLAUSTRAC’s reporting portalWhere the business enrols and lodges its reports.

Thresholds, deadlines and retention periods are deliberately not on this sheet. They change, and a printed page outlives the guidance it was copied from — read those from AUSTRAC’s current guidance.

3 · What to be alert to

FamilyWhat it looks like
Structures without a purposeA company or trust whose commercial rationale nobody can articulate. Layers that serve no tax, succession or operational reason. Reluctance to explain why the structure is wanted.
Distance between owner and entityA client asking that others be named as director, shareholder or trustee. Pressure to have the practice act as nominee. The person directing decisions is not the person on the documents.
Speed where speed is oddUrgency to have an entity ready. Interest in a shelf company rather than incorporating. No questions about cost, only about timing.
Address without presenceA registered office or business address requested with no activity behind it. Mail-forwarding arrangements that obscure who is really there.
Client money moving oddlyFunds received that exceed what the engagement requires. A request to disburse to a third party or a different account. Money that arrives and leaves without touching the work.
Profile and paperwork mismatchApparent wealth inconsistent with the stated business. Financial records that do not reconcile. Vagueness or irritation about source of funds or source of wealth.
Cross-border layeringEntities in secrecy jurisdictions with no commercial reason. Related parties overseas who never appear. Financing from sources the client will not identify.

Every one of these has an innocent explanation, and usually that is the right one. Two or three together, or a feeling you cannot articulate — escalate. Check AUSTRAC’s current guidance for your sector rather than treating this list as complete.

4 · Escalating

DoDo not
Record the facts you observed — who, what, when, what was actually said.Investigate it yourself or question the client to find out more.
Raise it on the client record, through your business’s own process.Tell the client, or anyone who does not need to know, that a report has been made or considered.
Do it the same day, while the detail is accurate.Decide privately that it is probably nothing.
Carry on with the matter professionally and normally.Change how warm you are. That is its own signal.

Write what you saw, not what you concluded. "Declined to meet in person three times and asked whether funds could come from two accounts" can be assessed. "Seemed dodgy" cannot.

5 · If a client asks why it is taking longer

"We need to complete some standard checks before we can proceed. They apply to every matter — I will let you know the moment we can move."

Use it for everybody, not only the files you are worried about. Checks that apply to everyone are not information about anyone — and a careful answer given only sometimes communicates the very thing you are avoiding saying.

Telling someone that a report has been made or is being considered is a criminal offence. If you think you may have said too much, tell your compliance officer straight away rather than trying to repair it yourself. Where the line falls in any particular case is a legal question for AUSTRAC’s guidance or your own adviser.

6 · Your business

Fill this in before you pin it up.

AML/CTF compliance officer
Phone / email
Backup contact if they are unavailable
Where escalations are raised

A process nobody can find is not a process. If the only person who knows how to escalate is on leave this fortnight, fill in the third line before you do anything else.

The AML/CTF acronym cheatsheet →The single-page version, if the full guide is more than you need.