A formation platform can prepare documents and lodge a registration while the accounting practice still takes meaningful steps in the client's transaction. To assess the practice's position, describe the acts each business performs. A supplier's statement that it handles AML does not resolve the practice's designated-service scope, identify which checks were performed or explain whether the practice can lawfully rely on them.
Map the service before mapping the supplier
List who obtains instructions, chooses or prepares the structure, supplies formation information, coordinates signatures and gives lodgement instructions. Assess the accounting practice's own acts against AUSTRAC's professional-services guidance. Distinguish a simple referral from work that directly advances formation. Both firms may have obligations for their respective services; a supplier invoice is not an allocation of statutory responsibility and a contract label is not a scope decision.
Identify which kind of arrangement you have
Separate outsourcing the formation task from outsourcing an AML function and from relying on CDD performed by another entity. These are different questions. AUSTRAC publishes distinct outsourcing and reliance guidance. Record which arrangement is being used for each part of the work and the basis for it. A forwarded identity document or vendor completion badge should not be treated as a compliant reliance arrangement without examining the applicable requirements.
Ask for evidence that supports the actual decision
For example, the provider may confirm a company was registered without confirming the proposed beneficial-owner information used by the practice. Agree which information and verification records can be supplied, when and through what secure channel. Identify what remains the practice's task. Check that the delivered records relate to the correct entity and people, rather than accepting a generic completion certificate. Record discrepancies and follow them to resolution.
Plan for exceptions and supplier failure
Keep a contact and escalation path for rejected documents, changed instructions, delayed records and suspected errors. Define who pauses the next implementation step and how the practice retrieves its records if the service ends. Review whether the actual delivery matches the arrangement and the practice's program. Avoid relying on an outsourced process that staff cannot explain, inspect or continue lawfully when the supplier is unavailable.
Official sources
Confirm the current rules against these primary sources, last checked .
Questions
Does using a formation agent remove the practice's obligations?
Not automatically. Assess the acts your practice performs and the legal basis for any outsourced AML work or reliance.
Is supplier registration proof enough for CDD?
It proves only what the record establishes. Identify the customer and other required matters, then assess whether the available evidence supports them.
Can the provider's general terms replace a reliance assessment?
No. Check the applicable legal conditions and records access for the particular arrangement rather than assuming a generic contract satisfies them.
General information for Australian professionals, not legal advice. It does not replace the AML/CTF Act, the Rules or AUSTRAC guidance. See our editorial standards.
Keep reading
- Company, trust and SMSF formation5 min
A service-based guide to when tax-agent work creating a company, trust or SMSF becomes a professional designated service and what must happen before the work starts.
- Outsourcing versus CDD reliance3 min
Identify whether another business performs AML functions, supplies a tool or provides CDD for lawful reliance, then document responsibilities and records access.
- Provider outages and manual work3 min
Separate technical failure from an adverse customer result, control the service boundary and use an alternative verification method only where permitted.