The scope test for a Sydney accountant
Bookkeeping, BAS preparation and ordinary individual tax returns are not designated services. The work that brings an accountant into scope is more structural: forming a company or trust on behalf of a client, acting as a nominee director or trustee, managing client funds in a trust account, or providing tax advice that includes structuring assets to obscure ownership.
If your Sydney practice does any of the above, even for a small share of clients, the whole practice enrols and the whole practice has a Program. There is no carve-out for practices where designated services are a small percentage of revenue. The obligation attaches whenever you provide the service.
- Company formation and acting as nominee director or shareholder
- Trust formation, especially discretionary and fixed unit trusts
- Managing client money in a trust or controlled-monies account
- Tax structuring advice with ownership-obscuring features
- Real estate transactions on behalf of a client (rare for accountants)
Sydney-specific risk indicators
AUSTRAC's published typology work flags Sydney as a high-risk geography for trust-and-company-service abuse, particularly the use of nominee directors to obscure beneficial ownership for offshore-controlled vehicles. Sydney accountants offering company formation or nominee services should expect enhanced scrutiny on the beneficial-ownership chain.
If a client requests a company structure where the legal-controller chain is more than two layers deep, expect to capture and document each layer down to the natural person. Caltury's customer form is built around this requirement; you do not progress to file-acceptance until each beneficial-owner layer is recorded.
Caltury for a Sydney accountant
The Caltury workflow for an accounting practice covers enrolment, an accounting-tailored Program, customer due diligence with beneficial-owner branching, sanctions and PEP screening, and the SMR / TTR / IFTI reporting workflow. The Program names the Tax Agent Services Act framework explicitly so it reads as written for a practising AU accountant rather than a generic financial-services template.
If the practice does company formations, the customer entity tree is captured at file-opening and re-verified at any change in ownership. Sanctions and PEP screening runs across every natural person identified in the tree, not just the named director. The output of every screen is retained for the full 7 years.
Common questions
We are a Sydney tax-only practice. Do we need to enrol with AUSTRAC?
Possibly not. If your work is genuinely tax-return preparation and tax advice without structuring or trust/company formation, you may sit outside the designated services. The readiness check walks through the scope test in 12 questions and gives a per-obligation diagnostic so you can make the call with confidence.
We outsource our company-formation work to a CSP. Are we still in scope?
It depends on whether you are the service-provider to the client or whether the CSP is. If the client engages you and you sub-contract the work, you are typically still the reporting entity. If the client engages the CSP directly via you as a referrer, the CSP carries the obligation. Document the engagement chain in writing.
Does CPA or CA ANZ accreditation reduce my obligations?
No. Professional body accreditation has no effect on AUSTRAC obligations. CPA Australia and CA ANZ both publish AML guidance for their members, but neither body has the power to vary or reduce AML/CTF obligations under the Act.
What does Caltury cost for a small Sydney accounting practice?
The Starter tier is A$99 a month plus GST for a sole practitioner. Practice (A$249) covers 2 to 5 person practices. Firm (A$499) covers 6 to 15. The Founding-10 program offers 50 percent off the chosen tier for three years for the first 10 paying customers.
This page is general information about Australian AML/CTF obligations. It is not legal advice. AUSTRAC has not reviewed this content. For situations specific to your practice consult an Australian-qualified lawyer or AML/CTF adviser.