Identify the action and outcome
A discussion about a transaction and active steps to advance it can have different scope consequences. AUSTRAC’s professional-services guidance explains this distinction for the relevant table 6 items. The assessment looks at the work actually done and its connection to the specified outcome. Do not turn the distinction into a universal exemption for advice. Check the exact item, the customer, the instructions and the stage reached. Other professional designated services use their own descriptions and need separate assessment.
- General discussion
Record the options discussed and the work initially agreed.
- Specific instruction
Identify the new action and intended outcome.
- Fresh scope check
Apply the relevant service item before performing the new work.
Check scope when instructions change
Example sequence for a changing engagement. Advice is not a universal exemption; the relevant table 6 item and its conditions still apply.
Follow the process from top to bottom.
Follow the engagement as it changes
A useful review starts with the customer’s original request and follows each later instruction. Note what the professional produces or does at each stage. Ask whether the work still explains general options or now performs steps for a specific outcome. Suggested evidence includes the engagement scope, instructions and work product. Labels such as advisory only should match those facts. If the label stays the same while the work changes, the label will not give staff a reliable scope control.
Example: from options to action
Consider a customer who first asks for a general discussion of business structures and later asks the firm to carry out steps to establish a chosen structure. The later request deserves a fresh scope check. The reviewer should identify the exact actions and relevant service item rather than treating the whole relationship as one unchanged advisory engagement. This example illustrates a change in instructions. It does not decide the legal result for every discussion, document or professional role involved in establishing a business.
Place the check before the step
Design intake and change-control questions around the point where instructions change. Give staff a way to pause and obtain a scope decision before performing the newly requested work. Record the decision and the associated customer process. Do not wait until billing to discover that an engagement moved into different work. For difficult boundaries, collect the actual facts and seek advice on the specific item. The most useful control is a clear handover between general discussion and assessed service delivery.
Use specific escalation facts
When asking for help, provide the proposed action and its intended outcome. A question such as does advice count is too broad to resolve reliably. Include the instructions, stage of the matter and work product. This allows the reviewer to apply the relevant guidance without guessing what the professional will actually do.