Cassandra AML

AML/CTF compliance software for accountants

A profession-specific AML/CTF workflow for Australian accountants providing entity, transaction, client-money, trust or company services under Tranche 2.

Five situations, in plain words

Illustrations of questions accountants and accounting practices meet. Not customers, and not a decision for your file.

  1. Year-end accounts on their own are usually not covered. Record that.

  2. Creating a trust or company for a client is often covered. Name the people behind it.

  3. Restructuring a group needs its own decision, even if you already do their tax.

  4. Holding client money for a purchase is different from sending an invoice.

  5. Acting as a nominee director is covered work. Do not treat it as admin.

Work that can be covered

  • Creating companies, trusts and legal arrangements
  • Entity restructuring
  • Holding or managing client funds or assets
  • Buying or selling businesses
  • Nominee, registered-office and TCSP work

What to keep on the file

  • Engagement-level designated-service decisions
  • ABN, ASIC and trust evidence
  • Ultimate beneficial-owner calculations
  • EDD and source-of-funds records
  • Partner approvals and audit history

Guides for accountants and accounting practices

Browse the accountants library

  • AML/CTF guide for accountants5 min

    A comprehensive guide for Australian accountants scoping professional designated services and operating risk-based AML/CTF controls from 1 July 2026.

  • Business-sale AML for accountants5 min

    How accountants distinguish advice and standalone valuation work from active assistance that directly advances a company or legal-arrangement sale or transfer.

  • Company, trust and restructure AML6 min

    A detailed guide to company and express-trust formation, item 6 legal-form restructuring and the service-specific customer due diligence accountants must perform.

  • Client money AML for accountants5 min

    A practical guide to receiving, holding, controlling or managing client property, direct advancement, payment boundaries and workflow controls for accountants.

  • Equity and debt finance AML6 min

    How accountants distinguish general advice from work advancing equity or debt finance for a body corporate, proposed body corporate or legal arrangement.

  • Accountant checklist3 min

    A file-ready AML/CTF checklist for accountants: designated services, entity ownership, source of funds, reporting, training and audit-ready records.

  • Practice risk assessment3 min

    How accounting firms structure an AUSTRAC-aligned ML/TF/PF risk assessment: services, customers, channels, geography and the controls that respond.

  • SMSF AML guide3 min

    When SMSF establishment or trustee services are designated for accountants, and the CDD, ownership and reporting duties that attach to them.

  • When an accounting engagement changes3 min

    Keep a clear service decision when routine accounting work moves into company formation, transaction assistance or another potentially designated service.

  • Who can instruct the practice?3 min

    Separate the customer, contact person and authorised representative when an accounting practice receives instructions for a designated service.

  • A discretionary-trust CDD file3 min

    Organise the deed, amendments, trustee authority, beneficiary descriptions and control analysis into a reviewable trust customer file.

  • Corporate trustees and control maps3 min

    Keep company shareholders and directors separate from trust roles when tracing the people relevant to an accounting client's designated service.

  • Existing client, different service3 min

    Review service scope, reusable evidence and the correct customer transition rules when a long-standing tax client requests different work.

  • Outsourced formation and responsibility3 min

    Document what the accounting practice and formation provider each do, separating designated-service scope from outsourced AML functions and CDD reliance.

  • Client-file review and handover3 min

    Review the reasoning and unresolved actions in an accounting AML file before another staff member takes responsibility for the next service step.

  • Client migration and AML triage3 min

    Import existing accounting contacts without confusing a successful data transfer with a completed service assessment, CDD decision or customer transition review.

Questions accountants and accounting practices ask

Are all accountants and accounting practices regulated by AUSTRAC?

No. It depends on whether the business provides a designated service with the required Australian link, not on the professional title. Assess each service and take advice where the boundary is uncertain.

What should accountants and accounting practices keep for an AML/CTF review?

The scope decision, customer and beneficial-owner evidence, the risk assessment, screening and escalation decisions, approvals, reporting records, training and the current AML/CTF program.

Does Cassandra AML replace legal advice?

No. It organises compliance work and evidence. It does not give legal advice, guarantee compliance or imply AUSTRAC endorsement.