Start with the work
A professional title is a useful starting point for research. It is not a complete scope decision. AUSTRAC explains that the service a business provides determines whether it is a reporting entity. A firm can perform several kinds of work, with different results for each. Start by listing the actual activities, the entity that performs them and the person who receives them. Then compare each activity with the relevant designated-service description. Keep the geographical link and any exclusion as separate questions.
- Describe work
Identify actual actions and output.
- Match the item
Compare with the relevant service description.
- Check conditions
Assess geographical link and exclusions.
- Record conclusion
Keep the reason and next process.
Map the service before deciding scope
Suggested scope-review sequence; the statutory criteria determine the result.
Follow the process from top to bottom.
Build a service map
A useful working table has one row for each materially different service. Suggested columns are the customer instruction, work performed, output delivered, responsible entity and possible designated-service item. Avoid rows labelled only accounting or legal work. Those labels hide the steps that matter. Use a recent engagement file to test whether the description matches practice. If staff use different descriptions for the same process, resolve the difference before you use the table to guide customer intake.
Example: a mixed practice
Consider an example firm that provides routine business support and also accepts instructions on entity formation. The practical task is to compare both workflows separately with the current rules. Do not assume that one result applies to every engagement. Ask who gives the instructions, what staff prepare and when the work moves beyond discussion. This example does not decide whether either service is regulated. It shows why a single profession-level yes or no can conceal important differences within the same business.
Use the result at intake
Once the scope decision is supported, translate it into a question that staff can answer before the relevant work starts. Link the answer to the correct procedure and identify who resolves uncertain cases. Keep the detailed legal reasoning behind the short intake question so that later reviewers can understand the design. Revisit the map when you add a service, change an engagement or alter the entity that performs it. A map describes your assessed service boundaries; it does not confirm compliance with all obligations.
Check the customer definition
For each possible service item, check who the Act identifies as the customer. The person who contacts your office may be acting for someone else. Record that distinction in the service map and refer identity questions to the relevant customer due diligence procedure. This prevents a scope label from concealing an unexamined customer relationship.