Overview of Designated Services in AML
- Meaning: A designated service is a service listed in section 6 of the AML and CTF Act that has been identified as posing a money laundering and terrorism financing risk and that meets the geographical link to Australia.
- Why it matters: If you provide a designated service, you are a reporting entity and you must enrol with AUSTRAC and meet AML and CTF obligations.
- Tranche 2 relevance: New designated services extend the regime to sectors such as real estate, professional services, and dealers in precious metals, stones and products from 1 July 2026.
- Key dates: Enrolment opens 31 March 2026. Obligations start 1 July 2026 for Tranche 2 entities. AUSTRAC+1
What is a designated service
AUSTRAC defines a designated service as a service listed in section 6 of the AML and CTF Act because it has been identified as posing a risk for money laundering and terrorism financing and which meets the geographical link.
This is the single most important gateway concept in the Australian AML and CTF regime. The regime does not apply to you because of your job title or your industry label. It applies because of the services you provide.
Why designated services are central to Tranche 2 compliance
If you provide one or more designated services, you are a reporting entity and must comply with obligations under the AML and CTF Act. AUSTRAC explains this clearly in its legislation guidance and its “who and what we regulate” material.
That is why Tranche 2 readiness begins with service mapping. You must be able to answer two questions confidently:
Do we provide a designated service.
Does it have the geographical link to Australia.
The geographical link requirement in plain English
AUSTRAC explains that you only have AML and CTF obligations for designated services if they have a geographical link to Australia, which is tested through concepts like providing the service at or through a permanent establishment in Australia.
For many Tranche 2 businesses, this means you are in scope if you are operating in Australia and providing the service from Australia, even if some clients are offshore.
Designated services for professional services under the reforms
AUSTRAC’s reform guidance for professional services provides a practical overview of the new designated services listed under table 6 of subsection 6(5B) of the Act. It includes, among other items, assisting in planning or executing transactions for real estate, buying or selling bodies corporate or legal arrangements, receiving or managing a person’s property to help execute a transaction, assisting with equity or debt financing, selling shelf companies, and providing registered office or principal place of business addresses.
This is particularly relevant to lawyers, conveyancers, accountants, and trust and company service providers.
What changes under the AML and CTF Amendment Act 2024
Government reform material explains that the Amendment Act updates AML and CTF program requirements so they focus on identifying, assessing, and mitigating money laundering, terrorism financing, and proliferation financing risk. It also introduces a simplified reporting group concept and clarifies roles of the governing body and compliance officer.
This matters because once you are in scope as a provider of a designated service, AUSTRAC expects you to run a program that actually manages risk, not one that merely exists.
Implementation timeline you should plan against
AUSTRAC’s reforms guidance on the new AML and CTF Rules sets out staged commencement:
31 March 2026: Changes to AML and CTF obligations start for current reporting entities, with some reporting remaining unchanged until later.
31 March 2026: Enrolment opens for newly regulated sectors, which includes Tranche 2.
1 July 2026: AML and CTF obligations start for Tranche 2 entities.
AUSTRAC also confirms that if you provide certain new designated services on 1 July 2026, you will have until 29 July 2026 to enrol, but enrolment itself cannot be done earlier than 31 March 2026.
Examples to help you identify designated service exposure
Example 1: Conveyancing support for a property transfer
If you assist in the planning or execution of a transaction to sell, buy, or transfer real estate, that is captured in the professional services designated services list in the reform guidance.
Example 2: Acting as a company officer nominee or arranging it
If you act, or arrange for someone to act, in certain positions in a body corporate or legal arrangement, that is also listed in the professional services reform guidance.
Example 3: Receiving and holding funds to help execute a transaction
If you receive, hold, control or manage a person’s property to help in planning or executing a transaction, that is explicitly listed.
These examples show why service mapping is the first step. A firm may think it is simply giving advice, but the actual work done may fall within a designated service.
Best practice for Tranche 2 service mapping
List all service lines in your business, including occasional work. AUSTRAC notes that “carrying on a business” is broad and can include providing a designated service even if it is not frequent.
Map each service line to the relevant table and item in section 6 of the Act, using AUSTRAC reform guidance where available for new sectors.
Confirm the geographical link. Consider where the work is performed, where your permanent establishment is, and where the customer receives the service.
Decide your operating model. If only part of your firm provides a designated service, define boundaries, controls, and training for that part, while ensuring enterprise wide oversight remains effective.
Build readiness milestones against the 31 March 2026 enrolment opening and the 1 July 2026 obligations start date.
Common challenges
Firms assume they are out of scope because they are not a bank.
Businesses underestimate how often they “assist in planning or executing” transactions.
Service descriptions are inconsistent across marketing, engagement letters, and actual delivery, which makes mapping harder.
Geographical link assumptions are not documented.
How Tranche 2 Consultants can help
Tranche 2 Consultants can run a structured designated service assessment for your business, map each service line to the Act, confirm your geographical link position, and produce an implementation plan aligned to AUSTRAC’s staged commencement dates. We then build your AML and CTF program, customer due diligence workflow, training plan, and reporting readiness so you can go live confidently.
Closing Notes on Designated Services
Designated service is the starting point of AML and CTF compliance in Australia. If you get this classification right early, everything else becomes simpler. Your program, your customer due diligence, your training, and your reporting readiness all become targeted and defensible.
“Bookmakers sit at a natural convergence point for cash, speed and anonymity. AUSTRAC’s focus reflects the reality that wagering platforms can be misused as value transfer mechanisms if risk controls are not actively applied.”
