Describe the work before deciding scope
AUSTRAC provides an accountant industry page and detailed professional designated-service guidance. Those sources make the actual work the starting point for a scope review. A practice can offer different services to the same client, and a general label such as accounting does not explain each one. This page helps organise that review. It does not treat every accounting task as a designated service or decide the legal position of an individual engagement. Read the current service conditions and relevant legislation before reaching that conclusion.
Directly advancing a transaction
For the real-estate professional service, the guidance distinguishes work that directly advances a transaction from advice about its consequences. Preparing transfer documents can advance the transaction. Advice about the financial consequences of withdrawing from it may not. The distinction is useful for accountants because transaction-related work is not one undivided category. Describe the specific assistance and when it occurs. The legal test must still be applied to the actual instructions; the fact that advice concerns a property does not settle the service classification.
- Transfer documents
Preparing documents can directly advance a transaction.
- Withdrawal advice
Advice on financial consequences may affect a decision without directly advancing it.
- Actual instructions
Apply the service test to the work performed, not simply the property-file label.
The task matters more than the file name
Read this visual with the source conditions and explanation in this section.
Separate evidence questions. An answer to one does not settle the others.
Worked example: a new company request
Imagine a client who usually requests routine accounting work asks the practice to help establish a company for a proposed transaction. In the example, the practice records the new instructions and checks the professional-services guidance. It does not rely only on the client’s history or the existing engagement name. If the review identifies a covered service, the practice follows the applicable process. The example shows a review trigger; it does not determine the result without the full service facts and legal conditions.
Clarify who gathers information
The example practice identifies which staff member requests customer information, which reviewer resolves uncertainty and who decides whether the file can move to the next stage. If an outside provider supplies identity information, record what it supplied and what the practice must still assess. Outsourcing work does not transfer the practice’s responsibility for its AML/CTF obligations. Recording those remaining tasks helps prevent staff from treating a file as complete merely because a document was uploaded. The actual program should follow the relevant current requirements.
Review the service inventory
A practical periodic discussion can compare the recorded service list with recent engagements. Ask whether new offerings or informal assistance are missing from the list. Use a few actual service descriptions, with appropriate confidentiality, rather than abstract labels. Record changes and assign follow-up to a named person. This proposed check supports a clearer scope map but does not confirm compliance. For the next steps, read the related program, customer due diligence and reporting guides.