The international category
DNFBP means designated non-financial business or profession. FATF uses this category for specified businesses and professions outside financial institutions.
The category includes casinos, real estate agents, precious-metal and precious-stone dealers, certain legal and accounting professionals, and trust and company service providers.
Source: FATF: Designated non financial businesses and professions.
Activities and conditions matter
FATF Recommendations 22 and 23 address customer due diligence and other measures for DNFBPs. Their requirements have activity conditions and, for some businesses, transaction thresholds.
The FATF category and its thresholds do not replace Australian law.
Source: FATF: Recommendations 22 and 23; Interpretive Note to Recommendations 22 and 23.
The Australian service test
Australia uses designated services to determine AML/CTF scope. The service description, required geographical link and applicable exemptions matter.
For professional services, table 6 of the Act describes specified activities. A professional title alone does not answer whether an activity is a designated service.
Source: AUSTRAC: Designated services; Key terms and principles.
- DNFBP
FATF groups specified businesses and professions in this category.
- Designated service
Australian scope depends on the service, its conditions and the required geographical link.
A category and a service test
A profession label alone does not complete the Australian scope test. Relevant exemptions and service conditions still matter.
Separate evidence questions. An answer to one does not settle the others.
Two accounting engagements
In a fictional practice, one engagement concerns general advice. Another concerns active steps to create a company for a client.
The accountant’s title is the same in both cases. The actual work differs. The practice must examine the relevant service conditions for each engagement.
The professional transaction article gives more detail about advice and active assistance. The service-scope article owns the full Australian scope process.
Source: AUSTRAC: Key terms and principles; Creating or restructuring a body corporate or legal arrangement.